Assess whether comparative files show second-review bias after a marketing

SITUATION After a marketing mailer that skipped majority-minority tracts, credit-card limit assignment disparity table is what CRA strategist can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

DECISION CRA strategist in a manufactured-housing lender with dealer-originated files 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for CRA strategist in a manufactured-housing lender with dealer-originated files. 4. Credit-card limit assignment disparity table is missing the fact CRA strategist needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for CRA strategist.

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 (credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.