Line Assignments Have a Disparate Impact the Bank Will Defend

Situation

In a mortgage company after a pricing-regression spike, credit-card limit assignment disparity table is the evidence after a community complaint about appraisal gaps. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using credit-card limit assignment disparity table.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike 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 community complaint about appraisal gaps.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a community complaint about appraisal gaps; 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 fair-lending officer in a mortgage company after a pricing-regression spike.
• Credit-card limit assignment disparity table is missing the fact fair-lending officer needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a community complaint about appraisal gaps and write the one fact that would move line assignments have a for fair-lending officer.

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 (credit-card limit assignment disparity table after a community complaint about appraisal gaps). If credit-card limit assignment disparity table cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.