Assess whether pricing disparities are justified by legitimate factors

SITUATION The working file is underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files. Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

DECISION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a DOJ or CFPB monitor request for pricing files. 3. A DOJ or CFPB monitor request for pricing files never reached the population in underwriting exception log by branch — reopen intake, do not close pricing disparities are justified. 4. Two facts in underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files conflict for adverse-action notice operations lead; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from underwriting exception log by branch. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files and write the one fact that would move pricing disparities are justified for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option underwriting exception log by branch can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.