Assess whether the exam response should concede a finding (f469dc)

SITUATION After a vendor score change with no disparate-impact test, mortgage pricing residual by prohibited-basis group is what adverse-action notice operations lead can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION Adverse-action notice operations lead 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 mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in mortgage pricing residual by prohibited-basis group is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in mortgage pricing residual by prohibited-basis group is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A credit-card issuer changing line-assignment logic already contained a vendor score change with no disparate-impact test before mortgage pricing residual by prohibited-basis group arrived; no new Examination and Notices path. 4. Provenance on mortgage pricing residual by prohibited-basis group 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. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 2. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a vendor score change with no disparate-impact test and write the one fact that would move the exam response should 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 / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.