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

SITUATION Pricing and Credit Limits work in a credit-card issuer changing line-assignment logic now turns on comparative files show second-review because a CRA PE that called the assessment area too narrow put SPCP written plan versus actual originations in play. Second-review underwriter should say what SPCP written plan versus actual originations proves.

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 SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from SPCP written plan versus actual originations; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow. 3. A CRA PE that called the assessment area too narrow never reached the population in SPCP written plan versus actual originations — reopen intake, do not close comparative files show second-review. 4. Two facts in SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow conflict for second-review underwriter; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table second-review underwriter cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review 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 (SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow). 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.