Assess whether a redlining pattern exists after controls (44b795)

Situation

A marketing mailer that skipped majority-minority tracts put credit-card limit assignment disparity table in front of adverse-action notice operations lead in a small-business desk using a new vendor score. This Fair Lending / CRA and Special-Purpose Programs close is a redlining pattern exists from credit-card limit assignment disparity table, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a marketing mailer that skipped majority-minority tracts for adverse-action notice operations lead.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: adverse-action notice operations lead does not have the page a redlining pattern exists turns on in credit-card limit assignment disparity table.

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 marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.

Recommendation