Digital Marketing and Big Data—Managing Fair Lending Risk
Author: Darren M. Welch.; Anand S. Raman.
Source: Volume 34, Number 11, November 2018 , pp.133-138(6)
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Abstract:
The advantages of digital marketing and “Big Data” have led banks and consumer finance companies, in recent years, to focus marketing efforts on internet and digital channels. While these tools are efficient, their use may create fair lending violations when model variables are correlated with prohibited factors. The authors discuss the issues and conclude with suggested best practices to mitigate fair lending risks.Keywords: Equal Credit Opportunity Act (“ECOA”); Fair Housing Act (“FHA”); Risk Mitigation Strategies
Affiliations:
1: Skadden, Arps, Slate, Meagher & Flom LLP; 2: Skadden, Arps.