The pain

Fair lending enforcement is accelerating. The CFPB has made clear that AI models producing disparate outcomes are as liable as human decision-makers — and penalties include individual and class action damages.

ECOA / Reg B Fair Lending (HMDA) DORA

Laws that likely apply to you

  • ECOA / Regulation B — adverse action notices required for AI credit decisions; equal opportunity in lending
  • Fair Lending (HMDA) — disparate impact analysis for AI lending models; fair lending testing
  • DORA — ICT risk management for AI vendors serving EU financial entities
  • NIS2 — cybersecurity for AI service providers in financial infrastructure

What we do

We help financial institutions and their AI vendors build fair lending compliance programs — disparate impact testing, adverse action documentation, and audit readiness. If customer financial data is flowing into a third-party AI system with no controls, see Temper Enclave for the architectural fix.

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Informational only — not legal advice. Consult qualified counsel for binding guidance.