Assess whether to pause a product pending a lookback (d40098)

SITUATION Credit-card limit assignment disparity table arrived with a DOJ or CFPB monitor request for pricing files for second-review underwriter. That is a Fair Lending CRA and Special-Purpose Programs decision on to pause a product in a lender expanding into majority-minority census tracts.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts 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 DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a DOJ or CFPB monitor request for pricing files for second-review underwriter. 3. Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision to pause a product turns on in credit-card limit assignment disparity table.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a DOJ or CFPB monitor request for pricing files 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in credit-card limit assignment disparity table, then the action for second-review underwriter - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - CRA and Special-Purpose Programs finding in credit-card limit assignment disparity table that a second reviewer can re-perform - Missing page in credit-card limit assignment disparity table after a DOJ or CFPB monitor request for pricing files, if any