Abstract
The FDIC proposes to designate private standards setting organizations (SSOs) and certifying organizations (COs) for use in the supervision of third party technology service providers (fintechs) that partner with banks in providing financial products and services. This comment cautions against the use of such third parties in bank supervision broadly and specifically in the context of the U.S. Department of Housing and Urban Development's August 2019 proposal to create expansive safe harbors from Fair Housing Act disparate impact liability when algorithmic models are using in risk assessments.
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