Assess whether line assignments have a disparate impact the bank will defend

SITUATION A credit-card issuer changing line-assignment logic cannot treat a SPCP that originated almost no loans to the intended class as incidental context on underwriting exception log by branch. Second-review underwriter must close line assignments have a from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Second-review underwriter 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after a SPCP that originated almost no loans to the intended class for second-review underwriter. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision line assignments have a turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table second-review underwriter cannot explain from underwriting exception log by branch. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a SPCP that originated almost no loans to the intended class and write the one fact that would move line assignments have a for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in underwriting exception log by branch, then the action for second-review underwriter - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - What changes line assignments have a if a SPCP that originated almost no loans to the intended class is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others