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NYDFS Vindicates Apple Card in Investigation on Discrimination Claims

The New York State Department of Financial Services ("NYDFS") investigated allegations of discrimination against women in the underwriting of the Apple Card. NYDFS found no evidence of violations under fair lending laws.

In a report, NYDFS stated that it reviewed the Apple Card policies for evidence of:

  • disparate treatment, including any evidence that the underwriter intentionally judged applicants based on sex; and
  • disparate impact, relying on the NYDFS's Consumer Examinations Unit to evaluate the underwriting data of nearly 400,000 New York applicants to determine whether credit decisions resulted in unequal outcomes.

NYDFS found that women and men with "equivalent credit characteristics" had comparable Apple Card application outcomes. In addition, after requesting the underwriter to explain credit decisions for individuals who made discrimination complaints, NYDFS found that in each instance the underwriter provided lawful factors (e.g., credit score, indebtedness, income, credit utilization, etc.) for the credit determination.

Primary Sources

  1. NYDFS Press Release: DFS Issues Findings on the Apple Card and its Underwriter Goldman Sachs Bank
  2. NYDFS Report: Report on Apple Card Investigation

Tags

Regulated Activities
Diversity / Discrimination
Sub-Activity
Equal Credit (ECOA) / Fair Lending
Regulated Entities
Banking Entities
Regulated Products
Bank Products
Sub-Product
Credit Cards
Body of Law
Banking Law
Jurisdiction
US - Federal
Organization
States
Sub-Author
NYDFS