Assess whether to pause a product pending a lookback after a board asking if

SITUATION CRA assessment-area versus lending footprint arrived with a board asking if the bank should settle a matched-pair study for second-review underwriter. That is a Fair Lending Pricing and Credit Limits decision on to pause a product in a credit-card issuer changing line-assignment logic.

DECISION Second-review underwriter 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 CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in CRA assessment-area versus lending footprint for second-review underwriter in a credit-card issuer changing line-assignment logic. 4. CRA assessment-area versus lending footprint is missing the fact second-review underwriter needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table second-review underwriter cannot explain from CRA assessment-area versus lending footprint. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a board asking if the bank should settle a matched-pair study and write the one fact that would move to pause a product for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a credit-card issuer changing line-assignment logic does not have.