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Framework for Managing Machine Learning Models in Consumer Credit Underwriting



Report Summary



This report details key considerations and approaches for managing machine learning underwriting models. The report reflects discussions with banks that participated in a Technology Working Group convened under the Office of the Comptroller of the Currency’s Project REACh (Roundtable for Economic Access and Change).

The report summarizes potential benefits of using machine learning underwriting models and describes how industry practices are evolving, while recognizing that data science techniques are continuing to progress and that lenders vary in their strategies and technical implementation. The broader goal of the document is to provide a practical framework outlining core risk management principles, processes, and issues that are helpful to consider in adopting machine learning models.  


Acknowledgments



This framework was developed through discussions with banks that participated in a Technology Working Group convened under the Office of the Comptroller of the Currency’s Project REACh (Roundtable for Economic Access and Change). It is intended to foster greater understanding among financial institutions, agency staff, and other stakeholders about how machine learning technologies are being used responsibly to facilitate innovation in credit underwriting. FinRegLab served as the co-chair of the working group and facilitator of the framework drafting process.


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