Assess whether a redlining pattern exists after controls (5a0fe0)

Situation

A redlining pattern exists sits with community-development lender because a vendor score change with no disparate-impact test hit an institution preparing for a redlining exam. Evidence is credit-card limit assignment disparity table; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Community-development lender in an institution preparing for a redlining exam 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 vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a vendor score change with no disparate-impact test for community-development lender.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: community-development lender does not have the page a redlining pattern exists turns on in credit-card limit assignment disparity table.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a vendor score change with no disparate-impact test). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.