Special-purpose Program: Well Designed or Pretext?

Situation

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program has one working extract — credit-card limit assignment disparity table — after a CRA PE that called the assessment area too narrow. If credit-card limit assignment disparity table cannot support a special-purpose program is, the honest Fair Lending output is hold.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• A CRA PE that called the assessment area too narrow is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given credit-card limit assignment disparity table.
• A CRA PE that called the assessment area too narrow is the event in credit-card limit assignment disparity table that forces A special-purpose program is well designed for adverse-action notice operations lead under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Pricing and Credit Limits program failure.
• Credit-card limit assignment disparity table cannot decide a special-purpose program is yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

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 credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• 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 special-purpose program is for adverse-action notice operations lead.

Recommendation