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Technological Exceptions: The CFPB's Embrace of Race-Based Credit Scoring Models
A recent CFPB publication directs lenders to use race-based debiasing methods for their credit models. Why is this a serious problem?

Richard Pace
Feb 1218 min read
315 views


Fool's Gold 4: The Brittleness of Algorithmic LDA Credit Models
This article examines the further risks and challenges of using less discriminatory alternative (LDA) credit models amid CFPB scrutiny.

Richard Pace
Sep 4, 202442 min read
455 views


Algorithmic Justice: What's Wrong With The Technologists' Credit Model Disparate Impact Framework
Current credit model disparate impact frameworks dispense justice algorithmically. But are they consistent with applicable fairness laws?

Richard Pace
May 21, 202438 min read
836 views


Navigating AI Transformation: Avoiding The Pitfalls of Algorithmic Sprawl
AI delivers rewards, but the C-suite/Board must address the risks of unchecked algorithmic sprawl diluting returns - governance is crucial.

Richard Pace
Mar 12, 202410 min read
114 views


The Road to Fairer AI Credit Models: Are We Heading in the Right Direction?
My research suggests that LDA credit models may pose risks to early adopters. What research priorities could put us on a more viable path?

Richard Pace
Jan 30, 202420 min read
359 views


Fool's Gold 3: Do LDA Credit Models Really Improve Fairness?
LDA Credit Models, believed to reduce credit barriers, may instead expand credit access inappropriately, thereby creating risks for lenders.

Richard Pace
Nov 25, 202330 min read
401 views


Fool's Gold 2: Is There Really a Low-Cost Accuracy-Fairness Trade-off?
The existence of similarly-predictive models with improved fairness is a foundational pillar of algorithmic debiasing. Is it actually true?

Richard Pace
Oct 25, 202320 min read
297 views


BISG Proxy Bias Redux: The Impact of the 2020 U.S. Census Data
How Does the Updated 2020 Census Data Impact the Accuracy of Race/Ethnicity Proxies and Fair Lending Disparity Estimates?

Richard Pace
Aug 8, 202328 min read
777 views


The Cross River Consent Order: Why Banks and Fintechs Should Be Concerned
The Order creates potentially serious conflicts on data and information sharing and fair lending compliance risk management responsibilities

Richard Pace
Jun 5, 202315 min read
937 views


The 10 Attributes of Highly-Effective Model Risk Managers
On the 12th anniversary of US regulatory guidance on model risk management, I discuss 10 attributes of highly-effective model risk managers.

Richard Pace
Apr 22, 202313 min read
1,332 views


Meta's Variance Reduction System: Is This the AI Fairness Solution We've Been Waiting For?
In this blog post, I review the promises and potential pitfalls of Meta's Variance Reduction System - a new tool to address algorithmic bias

Richard Pace
Mar 29, 202321 min read
660 views


Fool's Gold? Assessing the Case For Algorithmic Debiasing
Can we really achieve increased credit model fairness with minimal trade-offs?

Richard Pace
Jan 27, 202336 min read
1,154 views


Are Rising Interest Rates Impairing AI Credit Model Fairness?
How are macroeconomic conditions impacting AI credit model decisions and what does this imply for popular algorithmic de-biasing practices?

Richard Pace
Dec 14, 202210 min read
158 views


Using Explainable AI to Produce ECOA Adverse Action Reasons: What Are The Risks?
CFPB Circular 2022-03 raises questions about the use of Explainable AI to produce Adverse Action reasons. Here, I explore the key risks.

Richard Pace
Sep 15, 202225 min read
734 views


Algorithmic Bias and Alternative Data: Five Lessons From the DOJ's Meta Settlement
Where are federal regulators and enforcement agencies heading with their clear concerns over algorithmic bias in financial services?

Richard Pace
Aug 10, 202214 min read
516 views


Dark Skies Ahead: The CFPB's Brewing Algorithmic Storm
I examine the shifting winds in the CFPB's sentiment towards AI-based lending and describe two potential dangers brewing on the horizon.

Richard Pace
Jul 1, 202213 min read
627 views


Six Unanswered Fair Lending Questions Hindering AI Credit Model Adoption
In this post, I highlight 6 critical open questions related to AI bias for which consumer lenders need regulatory guidance.

Richard Pace
Jun 10, 202215 min read
719 views


Is the CFPB Adopting a New Fair Lending Proxy Methodology (BIFSG)?
What do we know about its properties, and are there important risks or limitations we should be evaluating now in anticipation of its use?

Richard Pace
May 16, 202217 min read
1,399 views


Debiasing AI Credit Models While Preserving Explainability
In this post, I do a deeper dive into the important interdependency of credit model explainability and fairness.

Richard Pace
Mar 11, 20229 min read
315 views


Four Potential Pitfalls of AI Credit Scoring Models
I lay out a few potential "under-the-radar" risks of AI credit models' underlying technologies and use of alternative data.

Richard Pace
Feb 10, 202214 min read
864 views


Six Fair Lending Focus Areas For 2022: What to Expect and How to Prepare
What's in store for lenders in 2022 as a new class of financial regulatory leaders ramp up their supervision and enforcement activities?

Richard Pace
Jan 12, 20228 min read
305 views
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