What is disparate impact testing?
Disparate impact testing requires quantitatively testing models for fairness with respect to classes of borrowers protected under the Equal Credit Opportunity...
Dr. Adam Gailey is a principal in the Financial Economics Practice of CRA and is based in Washington, DC. He specializes in financial services litigation and regulatory compliance.
Since returning to CRA in 2012, he has worked on numerous DOJ and CFPB investigations, class-action lawsuits, and regulatory compliance cases. His cases typically involve providing statistical and economic analyses of large amounts of data. Dr. Gailey’s work has focused on issues related to the use of overdraft protection, indirect auto finance, redlining, and fair lending.
In overdraft protection matters, Dr. Gailey has provided exposure and damage estimates as well as opinions on issues related to class certification, and assisted institutions in preparing transaction level data. In the indirect auto space, Dr. Gailey has directed analyses of underwriting, buy rate, and dealer reserve. He has helped indirect auto lenders set up dealer monitoring/escalation plans and developed customer remuneration strategies.
In addition to more traditional redlining and fair lending analyses, Dr. Gailey has a particular interest in the fair lending implications of AI, machine learning, and alternative data. Dr. Gailey has also provided guidance to FinTech’s on model documentation and validation policies and procedures.