Assess whether pricing disparities are justified by legitimate factors

SITUATION A credit-card issuer changing line-assignment logic cannot treat a DOJ or CFPB monitor request for pricing files as incidental context on small-business decline comparative file set. Model-risk partner for credit scoring must close pricing disparities are justified from that extract under Fair Lending / CRA and Special-Purpose Programs.

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 small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a DOJ or CFPB monitor request for pricing files for model-risk partner for credit scoring. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision pricing disparities are justified turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set 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 Model-risk partner for credit scoring should take Temporary compensating control on pricing disparities are justified unless small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files already proves Remove access or reverse the item for this CRA and Special-Purpose Programs packet in a credit-card issuer changing line-assignment logic. Keep Approve a documented exception live only while small-business decline comparative file set is missing the decision pricing disparities are justified turns on. The working test on small-business decline comparative file set is whether Flag any disparate-impact table model-risk partner for credit scoring cannot explain from .