CRA Insights

Fair lending: Considerations when searching for less discriminatory alternatives

April 2024

The Consumer Financial Protection Bureau increasingly expects institutions to explore less discriminatory alternatives (LDAs) as part of their disparate impact fairness analyses under the Equal Credit Opportunity Act and Fair Housing Act.

In this Insights, Adam Gailey discusses what is meant by “less discriminatory” and the complexities of comparing models on fairness and other business objectives.

Key contacts