Assess whether pricing disparities are justified by legitimate factors

SITUATION In a credit-card issuer changing line-assignment logic, credit-card limit assignment disparity table is the evidence after a vendor score change with no disparate-impact test. Model-risk partner for credit scoring has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using credit-card limit assignment disparity table.

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 credit-card limit assignment disparity table after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic. 4. Credit-card limit assignment disparity table is missing the fact model-risk partner for credit scoring needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from credit-card limit assignment disparity table. 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 credit-card limit assignment disparity table. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a vendor score change with no disparate-impact test 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 (credit-card limit assignment disparity table after a vendor score change with no disparate-impact test). If credit-card limit assignment disparity table cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If credit-card limit assignment disparity table after a vendor score change with no disparate-impact test 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.