Assess whether a redlining pattern exists after controls after a DOJ or CFPB

Situation

A DOJ or CFPB monitor request for pricing files put geographic application and origination heat map in front of second-review underwriter in a credit-card issuer changing line-assignment logic. This Fair Lending / Pricing and Credit Limits close is a redlining pattern exists from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a DOJ or CFPB monitor request for pricing files for second-review underwriter.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: second-review underwriter does not have the page a redlining pattern exists turns on in geographic application and origination heat map.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from geographic application and origination heat map.
• 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 geographic application and origination heat map.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a redlining pattern exists for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option geographic application and origination heat map can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for second-review underwriter in a credit-card issuer changing line-assignment logic.