Equalizing Credit Opportunity in Algorithms: Aligning Algorithmic Fairness Research with U.S. Fair Lending Regulation
Open accessAbstract
Credit is an essential component of financial wellbeing in America, and unequal access to it is a large factor in the economic disparities between demographic groups that exist today. Today, machine learning algorithms, sometimes trained on alternative data, are increasingly being used to determine access to credit, yet research has shown that machine learning can encode many different versions of "unfairness," thus raising the concern that banks and other financial institutions could---potentially unwittingly---engage in illegal discrimination through the use of this technology. In the US, there are laws in place to make sure discrimination does not happen in lending and agencies charged with enforcing them. However, conversations around fair credit models in computer science and in policy are often misaligned: fair machine learning research often lacks legal and practical considerations specific to existing fair lending policy, and regulators have yet to issue new guidance on how, if at all, credit risk models should be utilizing practices and techniques from the research community. This paper aims to better align these sides of the conversation. We describe the current state of credit discrimination regulation in the United States, contextualize results from fair ML research to identify the specific fairness concerns raised by the use of machine learning in lending, and discuss regulatory opportunities to address these concerns.
The claims and statistics of this paper haven’t been checked yet.
Run the check — free, no account needed. It reads the open-access text and checks the sources it cites.
Integrity signals
Registry
Cites
Statistics
Claims the paper makes
The claims and statistics of this paper haven’t been checked yet.
Run the check — free, no account needed. It reads the open-access text and checks the sources it cites.
Claims other papers make about this one
Each is checked against this paper’s own text: does it say what the citing paper says it does?
Implementing bias mitigation techniques enhances model fairness, leading to more impartial lending determinations.
“Implementing bias mitigation techniques enhances model fairness, leading to more impartial lending determinations [290-292].”
From AI Fairness in Data Management and Analytics: A Review on Challenges, Methodologies and Applications (2023) · cites this paper as [291]
Self-check
Percentages, sums and reported differences re-computed from the paper’s own numbers.
The self-check needs the paper’s full text.
The citation lists haven’t been fetched yet
References 35 · Cited by 24
Research works printed but not linked: 24
- [4][4] Grace M. Abuhamad. 2019. The fallacy of equating "blindness" with fairness : ensuring trust in machine learning applications to consumer credit . Thesis. Massachusetts Institute of Technology. https://dspace.mit.edu/handle/1721.1/122094 Accepted: 2019-09-16T18:17:15Z. -
- [11][11] Jeremiah Battle, Sandra Mitchell Wilmore, Alys I Cohen, Chi Chi Wu, Charles Delbaum, Emily Green Caplan, Geoff Walsh, and National Consumer Law Center. 2018. Credit discrimination (7th ed.). National Consumer Law Center Digital Library, Boston, MA. OCLC: 1049151480. -
- [15][15] Leo Breiman. 2001. Random forests. Machine learning 45, 1 (2001), 5-32. -
- [17][17] Joy Buolamwini and Timnit Gebru. 2018. Gender Shades: Intersectional Accuracy Disparities in Commercial Gender Classification. In Conference on Fairness, Accountability and Transparency . PMLR, 77-91. http://proceedings.mlr.press/ v81/buolamwini18a.html ISSN: 2640-3498. -
- [24][24] Irene Y. Chen, Fredrik D. Johansson, and David Sontag. 2018. Why is my classifier discriminatory?. In Proceedings of the 32nd International Conference on Neural Information Processing Systems (NIPS'18) . Curran Associates Inc., Red Hook, NY, USA, 3543-3554. -
- [26][26] Rohit Chopra. [n.d.]. Remarks of Director Rohit Chopra at a Joint DOJ, CFPB, and OCC Press Conference on the Trustmark National Bank Enforcement Action. https://www.consumerfinance.gov/about-us/newsroom/remarks-ofdirector-rohit-chopra-at-a-joint-doj-cfpb-and-occ-press-conference-on-thetrustmark-national-bank-enforcement-action/. -
- [27][27] Alexandra Chouldechova. 2017. Fair prediction with disparate impact: A study of bias in recidivism prediction instruments. Big data 5, 2 (2017), 153-163. -
- [32][32] Amanda Coston, Ashesh Rambachan, and Alexandra Chouldechova. 2021. Characterizing Fairness Over the Set of Good Models Under Selective Labels. In Proceedings of the 38th International Conference on Machine Learning (Proceedings of Machine Learning Research) , Marina Meila and Tong Zhang (Eds.), Vol. 139. PMLR, 2144-2155. https://proceedings.mlr.press/v139/coston21a.html -
- [43][43] Talia B Gillis. 2022. The Input Fallacy. Forthcoming in Minnesota Law Review (2022). -
- [46][46] Moritz Hardt, Eric Price, and Nathan Srebro. 2016. Equality of Opportunity in Supervised Learning. In Advances in Neural Information Processing Systems , D. Lee, M. Sugiyama, U. Luxburg, I. Guyon, and R. Garnett (Eds.), Vol. 29. Curran Associates, Inc. https://proceedings.neurips.cc/paper/2016/file/ 9d2682367c3935defcb1f9e247a97c0d-Paper.pdf -
- [47][47] Deborah Hellman. 2020. Measuring algorithmic fairness. Va. L. Rev. 106 (2020), 811. -
- [50][50] Lily Hu and Issa Kohler-Hausmann. 2020. What's sex got to do with fair machine learning? arXiv preprint arXiv:2006.01770 (2020). - · arXiv
- [57][57] Pauline Kim. 2022. Race-Aware Algorithms: Fairness, Nondiscrimination and Affirmative Action. Forthcoming in California Law Review (2022). -
- [56][56] Nathan Kallus and Angela Zhou. 2018. Residual unfairness in fair machine learning from prejudiced data. In International Conference on Machine Learning . PMLR, 2439-2448. -
- [63][63] Lydia T Liu, Sarah Dean, Esther Rolf, Max Simchowitz, and Moritz Hardt. 2018. Delayed impact of fair machine learning. In International Conference on Machine Learning . PMLR, 3150-3158. -
- [64][64] Scott M Lundberg and Su-In Lee. 2017. A unified approach to interpreting model predictions. Advances in neural information processing systems 30 (2017). -
- [66][66] Stephen L Morgan and Christopher Winship. 2015. Counterfactuals and causal inference . Cambridge University Press. -
- [73][73] Office of the Comptroller of the Currency. 1997. OCC Bulletin 1997-24: Credit Scoring Models: Examination Guidance. -
- [75][75] Devah Pager and Hana Shepherd. 2008. The sociology of discrimination: Racial discrimination in employment, housing, credit, and consumer markets. Annu. Rev. Sociol 34 (2008), 181-209. -
- [76][76] Judea Pearl. 2009. Causal inference in statistics: An overview. Statistics surveys 3 (2009), 96-146. -
- [78][78] Anya ER Prince and Daniel Schwarcz. 2020. Proxy Discrimination in the Age of Artificial Intelligence and Big Data. Iowa law review 105, 3 (2020), 1257-1318. Place: Iowa City Publisher: University of Iowa. -
- [77][77] Christopher L Peterson. 2015. Consumer Financial Protection Bureau Law Enforcement: An Empirical Review. Tul. L. Rev. 90 (2015), 1057. -
- [82][82] Lucas Siegmund. 2020. A Fintech Charter by Another Name. The Regulatory Review (2020). -
- [83][83] Rebecca Kelly Slaughter, Janice Kopec, and Mohamad Batal. 2021. Algorithms and Economic Justice: A Taxonomy of Harms and a Path Forward for the Federal Trade Commission. Yale Journal of Law & Technology Special Publication (2021). -
- Authors
- Kumar, I. E., Hines, K. E., & Dickerson, J. P.
- Affiliations
- Brown University (US)
- Arthur AI, New York City, NY, USA
- Venue
- Proceedings of the 2022 AAAI/ACM Conference on AI, Ethics, and Society
- Publisher
- ACM
- Published
- 2022-07-26
- Pages
- 357-368
- ISSN
- 3065-8365 (ISSN-L)
- OpenAlex
- W4288096742
- Cited by
- 24
- References
- 35
- Citations by year
- 2026: 7 · 2025: 6 · 2024: 4 · 2023: 7
- FWCI
- 4.22
- Type
- conference paper
- Language
- en
- Open access
- green
- arxiv.org
- Locations
- Proceedings of the AAAI/ACM Conference on AI Ethics and Society (publishedVersion)
- arXiv (Cornell University) (submittedVersion)
- arXiv (Cornell University) (cc-by)
- Topics
- Social Sciences › Safety Research › Ethics and Social Impacts of AI
- Social Sciences › Business, Management and Accounting › Accounting › Financial Distress and Bankruptcy Prediction
- Social Sciences › Business, Management and Accounting › Management Information Systems › FinTech, Crowdfunding, Digital Finance
- Keywords
- credit discrimination, algorithmic fairness, access to credit, algorithmic discrimination, credit risk modeling, economic inequality, regulatory guidelines, United States
About these checks
Registry, retraction, Cites and statistics results are computed, not judged, with one exception: a printed reference that no index lists is read once by a model before it counts as a citation error. Claims are extracted by a model and kept only when their quote appears verbatim in the text; each cited source is then checked, with a model’s help, for whether it says what the claim relies on. Those verdicts can be wrong — read the claim’s quote and the cited source before relying on one.
Statistics and arithmetic are recomputed, not judged.
Confidence bands are shown only for fields calibrated on our annotated test set. None is calibrated yet, so no band is shown.
What counts as a claim ›How we measure confidence ›How we check this ›
Are you an author, or do you see a problem with this page? Request a review