Assess whether notices match the actual decisioning reasons (44c587)

SITUATION Examination and Notices work in a lender expanding into majority-minority census tracts now turns on notices match the actual because a CRA PE that called the assessment area too narrow put credit-card limit assignment disparity table in play. Examination and Notices work in a lender expanding into majority-minority census tracts now turns on notices match the actual because a CRA PE that called the assessment area too narrow put credit-card limit assignment disparity table in play; model-risk partner for credit scoring should say what credit-card limit assignment disparity table proves for Fair Lending.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. 4. Credit-card limit assignment disparity table is missing the fact model-risk partner for credit scoring needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table 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 model-risk partner for credit scoring cannot explain from credit-card limit assignment disparity table. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a CRA PE that called the assessment area too narrow and write the one fact that would move notices match the actual for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.