Assess whether dealer overlays introduce prohibited steering after a CRA PE

SITUATION A live Fair Lending Pricing and Credit Limits file in a credit-card issuer changing line-assignment logic now turns on model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow. Second-review underwriter should state what that extract proves for whether dealer overlays introduce prohibited steering.

DECISION Second-review underwriter 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 model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in model-reason-code mapping that does not match notices for second-review underwriter in a credit-card issuer changing line-assignment logic. 4. Model-reason-code mapping that does not match notices is missing the fact second-review underwriter needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from model-reason-code mapping that does not match notices. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a credit-card issuer changing line-assignment logic does not have.