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Richard Pace
Sep 3, 202441 min read
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.
406 views
Richard Pace
May 21, 202438 min read
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?
779 views
Richard Pace
Mar 12, 202410 min read
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.
113 views
Richard Pace
Jan 30, 202420 min read
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?
337 views
Richard Pace
Nov 25, 202330 min read
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.
373 views
Richard Pace
Oct 25, 202320 min read
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?
284 views
Richard Pace
Aug 8, 202328 min read
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?
701 views
Richard Pace
Jun 5, 202315 min read
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
848 views
Richard Pace
Apr 22, 202313 min read
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.
1,312 views
Richard Pace
Mar 29, 202321 min read
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
609 views
Richard Pace
Jan 27, 202336 min read
Fool's Gold? Assessing the Case For Algorithmic Debiasing
Can we really achieve increased credit model fairness with minimal trade-offs?
1,060 views
Richard Pace
Dec 14, 202210 min read
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?
147 views
Richard Pace
Sep 15, 202225 min read
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.
688 views
Richard Pace
Aug 10, 202214 min read
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?
498 views
Richard Pace
Jul 1, 202213 min read
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.
624 views
Richard Pace
Jun 10, 202215 min read
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.
698 views
Richard Pace
May 15, 202217 min read
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?
1,323 views
Richard Pace
Mar 11, 20229 min read
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.
305 views
Richard Pace
Feb 10, 202214 min read
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.
845 views
Richard Pace
Jan 12, 20228 min read
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?
304 views
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