Assess whether to pause a product pending a lookback (d108f9)

SITUATION Credit-card limit assignment disparity table arrived with a vendor score change with no disparate-impact test for CRA strategist. That is a Fair Lending CRA and Special-Purpose Programs decision on to pause a product in a mortgage company after a pricing-regression spike.

DECISION CRA strategist in a mortgage company after a pricing-regression spike 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. CRA strategist can defend Remove access or reverse the item from credit-card limit assignment disparity table after a vendor score change with no disparate-impact test in a Fair Lending challenge. 2. CRA strategist 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 a vendor score change with no disparate-impact test. 3. A vendor score change with no disparate-impact test 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 a vendor score change with no disparate-impact test conflict for CRA strategist; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a vendor score change with no disparate-impact test and write the one fact that would move to pause a product for CRA strategist.

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 vendor score change with no disparate-impact test). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for CRA strategist in a mortgage company after a pricing-regression spike.

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 CRA strategist - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Owner and next date for CRA strategist in a mortgage company after a pricing-regression spike - What changes to pause a product if a vendor score change with no disparate-impact test is later withdrawn