Assess whether a redlining pattern exists after controls (03f411)

Situation

Credit-card limit assignment disparity table arrived with an exception rate twice as high for one group after credit controls for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on a redlining pattern exists in a small-business desk using a new vendor score.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population in credit-card limit assignment disparity table is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in credit-card limit assignment disparity table is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained an exception rate twice as high for one group after credit controls before credit-card limit assignment disparity table arrived; no new CRA and Special-Purpose Programs path.
• Provenance on credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a small-business desk using a new vendor score 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 an exception rate twice as high for one group after credit controls and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.

Recommendation