Whether dealer overlays introduce prohibited steering from credit-card limit

Situation

In a credit union rolling out a special-purpose credit program, credit-card limit assignment disparity table is the evidence after a board asking if the bank should settle a matched-pair study. Adverse-action notice operations lead 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

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Adverse-action notice operations lead 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 board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in credit-card limit assignment disparity table — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits file.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.