Whether notices match the actual decisioning reasons from credit-card limit

Situation

Second-review underwriter in a credit-card issuer changing line-assignment logic has one working extract — credit-card limit assignment disparity table — after a notice that cites 'other' as the principal reason 40% of the time. If credit-card limit assignment disparity table cannot support notices match the actual, the honest Fair Lending output is hold.

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 credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled Pricing and Credit Limits process in a credit-card issuer changing line-assignment logic, given credit-card limit assignment disparity table.
• A notice that cites 'other' as the principal reason 40% of the time is the event in credit-card limit assignment disparity table that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Pricing and Credit Limits program failure.
• Credit-card limit assignment disparity table cannot decide notices match the actual yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic 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 notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move notices match the actual for second-review underwriter.

Recommendation