Assess whether comparative files show second-review bias (0cee6e)

Situation

Comparative files show second-review sits with adverse-action notice operations lead because a CRA PE that called the assessment area too narrow hit a small-business desk using a new vendor score. Evidence is credit-card limit assignment disparity table; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Credit-card limit assignment disparity table 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.
• Credit-card limit assignment disparity table 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 CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for adverse-action notice operations lead in a small-business desk using a new vendor score.
• Credit-card limit assignment disparity table is missing the fact adverse-action notice operations lead needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.