Assess whether dealer overlays introduce prohibited steering after a DOJ

SITUATION After a DOJ or CFPB monitor request for pricing files, underwriting exception log by branch is what second-review underwriter can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this 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 underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in underwriting exception log by branch for second-review underwriter in a credit-card issuer changing line-assignment logic. 4. Underwriting exception log by branch is missing the fact second-review underwriter needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 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 a DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited 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 a DOJ or CFPB monitor request for pricing files). If underwriting exception log by branch cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a credit-card issuer changing line-assignment logic does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on dealer overlays introduce prohibited, then the evidence in underwriting exception log by branch, then the action for second-review underwriter - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Owner and next date for second-review underwriter in a credit-card issuer changing line-assignment logic - What changes dealer overlays introduce prohibited if a DOJ or CFPB monitor request for pricing files is later withdrawn