Assess whether comparative files show second-review bias after a branch that

SITUATION The working file is model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP. Second-review underwriter in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

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 model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Pricing and Credit Limits process in a credit-card issuer changing line-assignment logic, given model-reason-code mapping that does not match notices. 2. A branch that stopped taking applications in one ZIP is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for second-review underwriter under Fair Lending. 3. Model-reason-code mapping that does not match notices shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Pricing and Credit Limits program failure. 4. Model-reason-code mapping that does not match notices cannot decide comparative files show second-review yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against comparative files show second-review. 2. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table second-review underwriter cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a branch that stopped taking applications in one ZIP and write the one fact that would move comparative files show second-review for second-review underwriter.

RECOMMENDATION The actionable close on model-reason-code mapping that does not match notices is Remove access or reverse the item if a branch that stopped taking applications in one ZIP left a complete Pricing and Credit Limits trail; otherwise Temporary compensating control. Second-review underwriter should cite the specific line in model-reason-code mapping that does not match notices that settles comparative files show second-review before anyone else acts in a credit-card issuer changing line-assignment logic.