ECOA Credit Denial and the use of AI

In this podcast, Dean and Len discuss the September guidance from the CFPB concerning the Equal Credit Opportunity Act (ECOA), credit denials, and Artificial Intelligence (AI). The guidance emphasizes that lenders using AI for credit decisions must provide specific and accurate reasons for adverse actions. This includes updates to sample adverse action forms and checklists to reflect actual reasons for credit denials or changes in conditions. The discussion also touches on potential updates to Home Mortgage Disclosure Act (HMDA) data collection to align with these expanded reasons for adverse action. Dean advises lenders to update ECOA assessments, review policies, procedures, forms, and ensure compliance and substantiation in credit decisions, especially in the context of AI and complex algorithms.

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