Assess whether the exam response should concede a finding (d1a96b)

SITUATION After a vendor score change with no disparate-impact test, credit-card limit assignment disparity table is what exam-response coordinator can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality 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 1. The population in credit-card limit assignment disparity table is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in credit-card limit assignment disparity table is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a vendor score change with no disparate-impact test before credit-card limit assignment disparity table arrived; no new Redlining and HMDA Data path. 4. Provenance on credit-card limit assignment disparity table after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Redlining and HMDA Data 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 the exam response should for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data 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 exam-response coordinator in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in credit-card limit assignment disparity table, then the action for exam-response coordinator - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Owner and next date for exam-response coordinator in a bank with thin HMDA LAR quality - What changes the exam response should if a vendor score change with no disparate-impact test is later withdrawn