Assess whether line assignments have a disparate impact the bank will defend

SITUATION A DOJ or CFPB monitor request for pricing files put appraisal-gap outcomes in majority-minority tracts in front of adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. This Fair Lending / Examination and Notices close is line assignments have a from appraisal-gap outcomes in majority-minority tracts, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. 4. Appraisal-gap outcomes in majority-minority tracts is missing the fact adverse-action notice operations lead needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from appraisal-gap outcomes in majority-minority tracts. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a DOJ or CFPB monitor request for pricing files and write the one fact that would move line assignments have a for adverse-action notice operations lead.

RECOMMENDATION Release Remove access or reverse the item for this Fair Lending Examination and Notices file only when appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files names the fact line assignments have a requires. Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic should withhold Remove access or reverse the item while that fact is still a hole in appraisal-gap outcomes in majority-minority tracts.