Whether the CRA plan is strategy or window dressing from credit-card limit

SITUATION An underwriter chat that used coded language put credit-card limit assignment disparity table in front of second-review underwriter in a credit-card issuer changing line-assignment logic. This Fair Lending / Pricing and Credit Limits decision is the CRA plan is from credit-card limit assignment disparity table, and the live options are The CRA plan is strategy, Window dressing.

DECISION Second-review underwriter in a credit-card issuer changing line-assignment logic must choose The CRA plan is strategy / Window dressing using credit-card limit assignment disparity table after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; credit-card limit assignment disparity table already has the discriminator after an underwriter chat that used coded language. 2. Keep Window dressing in force until credit-card limit assignment disparity table is completed after an underwriter chat that used coded language for second-review underwriter. 3. Treat credit-card limit assignment disparity table as The CRA plan is strategy because both readings appear after an underwriter chat that used coded language. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision the CRA plan is turns on in credit-card limit assignment disparity table.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 2. Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table. 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 credit-card limit assignment disparity table against an underwriter chat that used coded language and write the one fact that would move the CRA plan is for second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Pricing and Credit Limits packet (credit-card limit assignment disparity table after an underwriter chat that used coded language). If credit-card limit assignment disparity table 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.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in credit-card limit assignment disparity table, then the action for second-review underwriter - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in credit-card limit assignment disparity table that a second reviewer can re-perform