Assess whether a redlining pattern exists after controls (74a73b)

Situation

The Examination and Notices desk packet is small-business decline comparative file set after an exception rate twice as high for one group after credit controls. Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending 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 small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after an exception rate twice as high for one group after credit controls for adverse-action notice operations lead.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: adverse-action notice operations lead does not have the page a redlining pattern exists turns on in small-business decline comparative file set.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against an exception rate twice as high for one group after credit controls and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.