Assess whether pricing disparities are justified by legitimate factors

SITUATION An exception rate twice as high for one group after credit controls put small-business decline comparative file set in front of second-review underwriter in a credit-card issuer changing line-assignment logic. This Fair Lending / Pricing and Credit Limits close is pricing disparities are justified from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after an exception rate twice as high for one group after credit controls for second-review underwriter. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: second-review underwriter 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 second-review underwriter 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 Pricing and Credit Limits file, read small-business decline comparative file set against an exception rate twice as high for one group after credit controls and write the one fact that would move pricing disparities are justified 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 (small-business decline comparative file set after an exception rate twice as high for one group after credit controls). 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.