News & Analysis as of

Credit Discrimination Algorithms

Sheppard Mullin Richter & Hampton LLP

You Don’t Need a Machine to Predict What the FTC Might Do About Unsupported AI Claims

The rapid rise of AI used with advertising, marketing and other consumer facing applications has caused the FTC to continue to take notice and issues guidance. For example, the FTC is concerned about false or unsubstantiated...more

Cadwalader, Wickersham & Taft LLP

No, Fancy Technology Does Not Excuse Compliance Obligations

The Consumer Financial Protection Bureau (“CFPB”) released a regulatory Circular providing guidance regarding the use of “complex algorithms” to assess whether a consumer should be extended credit. Often referred to as “black...more

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