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The AI LendScape Blog
Exploring how AI is reshaping consumer lending - and what regulators, compliance teams, and counsel need to know.
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Unsafe and Unsound: A New Analysis of the CFPB's Misuse of BISG Race Proxies for Disparate Impact Enforcement
A validation the CFPB never ran: its BISG regression roughly doubled the disparities behind $160M+ in indirect-auto enforcement.

Richard Pace, PhD
Aug 2746 min read


Regulation B(eware): Is Algorithmic Debiasing Now Intentional Proxy Discrimination?
New Reg B drops disparate impact—but its direction-agnostic proxy test may recast debiased 'LDA' credit models as disparate treatment.

Richard Pace, PhD
Jun 114 min read


Disparate Impact is Dead. Long Live Disparate Impact.
The 2025 EO didn't kill disparate impact — SCOTUS settled that in Inclusive Communities. But agency enforcement overreach may have invited the blow.

Richard Pace, PhD
Jul 11, 202543 min read


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, PhD
Feb 12, 202518 min read


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

Richard Pace, PhD
Sep 4, 202442 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?

Richard Pace, PhD
May 21, 202438 min read


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

Richard Pace, PhD
Mar 12, 202410 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?

Richard Pace, PhD
Jan 30, 202420 min read


Fool's Gold 3: Does Automated Debiasing Really Improve Fair Lending Compliance?
LDA Credit Models, believed to reduce credit barriers, may instead expand credit access inappropriately, thereby creating risks for lenders.

Richard Pace, PhD
Nov 25, 202330 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?

Richard Pace, PhD
Oct 25, 202320 min read
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