Assess whether pricing disparities are justified by legitimate factors

SITUATION Redlining and HMDA Data work in an institution preparing for a redlining exam now turns on pricing disparities are justified because an exception rate twice as high for one group after credit controls put credit-card limit assignment disparity table in play. CRA strategist should say what credit-card limit assignment disparity table proves.

DECISION CRA strategist in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after an exception rate twice as high for one group after credit controls for CRA strategist. 3. Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: CRA strategist does not have the decision pricing disparities are justified turns on in credit-card limit assignment disparity table.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against an exception rate twice as high for one group after credit controls and write the one fact that would move pricing disparities are justified for CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option credit-card limit assignment disparity table can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.