Assess whether comparative files show second-review bias (52a414)

Situation

Adverse-action notice operations lead owns comparative files show second-review inside a credit-card issuer changing line-assignment logic with geographic application and origination heat map as the only packet. A CRA PE that called the assessment area too narrow is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Adverse-action notice operations lead 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from geographic application and origination heat map after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from geographic application and origination heat map; 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 geographic application and origination heat map — reopen intake, do not close comparative files show second-review.
• Two facts in geographic application and origination heat map after a CRA PE that called the assessment area too narrow conflict for adverse-action notice operations lead; hold this Examination and Notices file.

Analysis required

• 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.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.

Recommendation