Assess whether a redlining pattern exists after controls after an exception

Situation

After an exception rate twice as high for one group after credit controls, underwriting exception log by branch is what second-review underwriter can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

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 underwriting exception log by branch after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from underwriting exception log by branch after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in underwriting exception log by branch — reopen intake, do not close a redlining pattern exists.
• Two facts in underwriting exception log by branch after an exception rate twice as high for one group after credit controls conflict for second-review underwriter; hold this Pricing and Credit Limits file.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch 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 second-review underwriter.

Recommendation