Second-review underwriter must resolve whether comparative files show

Situation

Comparative files show second-review sits with second-review underwriter because a vendor score change with no disparate-impact test hit a credit-card issuer changing line-assignment logic. Evidence is credit-card limit assignment disparity table; write the Fair Lending Pricing and Credit Limits option that extract can carry.

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 credit-card limit assignment disparity table after a vendor score change with no disparate-impact test.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from credit-card limit assignment disparity table after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in credit-card limit assignment disparity table — reopen intake, do not close comparative files show second-review.
• Two facts in credit-card limit assignment disparity table after a vendor score change with no disparate-impact test conflict for second-review underwriter; hold this Pricing and Credit Limits file.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review 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 (credit-card limit assignment disparity table after a vendor score change with no disparate-impact test). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for second-review underwriter in a credit-card issuer changing line-assignment logic.