Assess whether a redlining pattern exists after controls (e3ad72)

Situation

A redlining pattern exists sits with adverse-action notice operations lead because a vendor score change with no disparate-impact test hit a credit-card issuer changing line-assignment logic. Evidence is small-business decline comparative file set; write the Fair Lending Examination and Notices option that extract can carry.

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 a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled Examination and Notices process in a credit-card issuer changing line-assignment logic, given small-business decline comparative file set.
• A vendor score change with no disparate-impact test is the event in small-business decline comparative file set that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• Small-business decline comparative file set shows a one-file miss after a vendor score change with no disparate-impact test, not a Examination and Notices program failure.
• Small-business decline comparative file set cannot decide a redlining pattern exists yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.

Recommendation