Assess whether a redlining pattern exists after controls from credit-card

Situation

In a manufactured-housing lender with dealer-originated files, credit-card limit assignment disparity table is the evidence after a CRA PE that called the assessment area too narrow. CRA strategist 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

CRA strategist in a manufactured-housing lender with dealer-originated files 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

• CRA strategist can defend Remove access or reverse the item from credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in credit-card limit assignment disparity table — reopen intake, do not close a redlining pattern exists.
• Two facts in credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow conflict for CRA strategist; hold this Pricing and Credit Limits file.

Analysis required

• 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.
• Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Pricing and Credit Limits 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 a redlining pattern exists for CRA strategist.

Recommendation