Assess whether to pause a product pending a lookback (09e36d)

SITUATION A credit union rolling out a special-purpose credit program cannot treat an exception rate twice as high for one group after credit controls as incidental context on credit-card limit assignment disparity table. Second-review underwriter must close to pause a product from that extract under Fair Lending / Examination and Notices.

DECISION Second-review underwriter in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls never reached the population in credit-card limit assignment disparity table — reopen intake, do not close to pause a product. 4. Two facts in credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls conflict for second-review underwriter; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against an exception rate twice as high for one group after credit controls 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 / Examination and Notices packet (credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls). If credit-card limit assignment disparity table cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a credit union rolling out a special-purpose credit program does not have.