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

SITUATION In a credit-card issuer changing line-assignment logic, a vendor score change with no disparate-impact test put adverse-action notice principal-reason sample in play. Second-review underwriter should decide whether line assignments have a disparate impact the bank will defend without filling gaps adverse-action notice principal-reason sample does not contain.

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 adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Adverse-action notice principal-reason sample is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in adverse-action notice principal-reason sample for second-review underwriter in a credit-card issuer changing line-assignment logic. 4. Adverse-action notice principal-reason sample is missing the fact second-review underwriter needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table second-review underwriter cannot explain from adverse-action notice principal-reason sample. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a 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 (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). If adverse-action notice principal-reason sample 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.