Assess whether pricing disparities are justified by legitimate factors

SITUATION After a DOJ or CFPB monitor request for pricing files, CRA assessment-area versus lending footprint is what model-risk partner for credit scoring can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Model-risk partner for credit scoring 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 CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. The population in CRA assessment-area versus lending footprint is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in CRA assessment-area versus lending footprint is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call. 3. A credit-card issuer changing line-assignment logic already contained a DOJ or CFPB monitor request for pricing files before CRA assessment-area versus lending footprint arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a DOJ or CFPB monitor request for pricing files and write the one fact that would move pricing disparities are justified for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.