Exam-response coordinator must resolve whether comparative files show

Situation

Pricing and Credit Limits work in an institution preparing for a redlining exam now turns on comparative files show second-review because a SPCP that originated almost no loans to the intended class put credit-card limit assignment disparity table in play. Exam-response coordinator should say what credit-card limit assignment disparity table proves.

Decision

Exam-response coordinator in an institution preparing for a redlining exam 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for exam-response coordinator in an institution preparing for a redlining exam.
• Credit-card limit assignment disparity table is missing the fact exam-response coordinator needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table exam-response coordinator cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation