Assess whether comparative files show second-review bias after an exception

SITUATION Underwriting exception log by branch arrived with an exception rate twice as high for one group after credit controls for second-review underwriter. That is a Fair Lending Pricing and Credit Limits decision on comparative files show second-review in a credit-card issuer changing line-assignment logic.

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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch 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 underwriting exception log by branch is completed after an exception rate twice as high for one group after credit controls for second-review underwriter. 3. Treat underwriting exception log by branch 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 comparative files show second-review turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against comparative files show second-review. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 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 an exception rate twice as high for one group after credit controls 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 (underwriting exception log by branch after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option underwriting exception log by branch can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for second-review underwriter in a credit-card issuer changing line-assignment logic.