Policy Memo Competition Second Place Winner
Policy Memo: Algorithm Transparency through the Fair Credit Reporting Act (FCRA)
Karl Schmeckpeper (1,3)*, Sonia Roberts (1,3)*+, Mathieu Ouellet (1,3)*, Matthew Malencia (1,3)*, Divya Jain (1,3)*, Walker Gosrich (1,3)*, Val Bromberg (2,3)*
+The author submitted this article in a personal capacity and was accepted prior to joining the JSPG editorial board. They did not contribute to selecting or editing the article as an editorial board member. Corresponding Author: [email protected] |
Keywords: housing discrimination, fair housing, algorithm transparency, algorithm bias, artificial intelligence (AI), Federal Trade Commission (FTC)
Executive Summary: Racial discrimination in housing has long fueled disparities in homeownership and wealth in the United States. Now, automated algorithms play a dominant role in rental and lending decisions. Advocates of these technologies argue that mortgage lending algorithms reduce discrimination. However, “errors in background check reports persist and remain pervasive,” and algorithms are at risk for inheriting prejudices from society and reflect pre-existing patterns of inequality. Additionally, algorithmic discrimination is often challenging to identify and difficult to explain or prosecute in court. While the Federal Trade Commission (FTC) is responsible for prosecuting this type of discrimination under the Fair Credit Reporting Act (FCRA), their enforcement regime “has inadequately regulated industry at the federal and state level and failed to provide consumers access to justice at an individual level,” as evidenced by its mere eighty-seven enforcement actions in the past forty years. In comparison, 4,531 lawsuits have been brought under the FCRA by other groups in 2018 alone. Therefore, the FTC must update its policies to ensure it can identify, prosecute, and facilitate third-party lawsuits against a primary driver of housing discrimination in the 21st century: discrimination within algorithmic decision making. We recommend that the FTC issue a rule requiring companies to publish a data plan with all consumer reporting products. Currently, the FTC recommends that companies make an internal assessment of the components of the proposed data plan to ensure that they are not in violation of the FCRA. Therefore, requiring that these plans be published publicly does not place undue burden on companies and empowers consumers to advocate for themselves and report unfair practices to the FTC. Coupled together, these will reduce the costs of investigation and enforcement by the FTC and decrease the discriminatory impact of automated decision systems on marginalized communities.
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Karl Schmeckeper is a Ph.D. student in Computer Science at the University of Pennsylvania. He works with Prof. Kostas Daniilidis in the Daniilidis Group, a computer vision and robotics research group in the General Robotics, Automation, Sensing, and Perception (GRASP) Lab. His Ph.D. work focuses on enabling robots to learn by encoding priors into machine learning models, by improving exploration, and by leveraging human demonstrations. Karl has a bachelor’s degree in computer science from the University of Massachusetts Amherst and a master’s degree in robotics from the University of Pennsylvania.
Sonia Roberts is a Ph.D. student in Electrical and Systems Engineering at the University of Pennsylvania. She works with Prof. Dan Koditschek in Kod*Lab, a legged robotics research group in the General Robotics, Automation, Sensing, and Perception (GRASP) Lab. Her Ph.D. work focuses on locomotion on soft, fragile substrates like sand, and how robots can respond to these difficult environments without needing complex internal models of them. Sonia's undergraduate degree is from Vassar College where she studied Cognitive Science, and she spent two years working as a research technician at the Howard Hughes Medical Institute's Janelia Farm Research Campus before coming to Penn.
Mathieu Ouellet is a Ph.D. student in Electrical and Systems Engineering at the University of Pennsylvania. He works with Prof. Danielle Bassett in the Complex Systems Lab UPenn, a multidisciplinary laboratory interested in the many facets of Complex Systems. He also works with Prof. Lee Bassett in the Quantum Engineering Lab @Upenn, a research group focused on understanding and controlling nanoscale quantum properties in semiconductor materials. His Ph.D. work focuses on understanding the properties of systems of multiple interacting components. Mathieu has a bachelor’s degree in computer science and physics from the University of Quebec. He also completed a master’s degree in applied mathematics, where he studied supersymmetry and the power spectral parameter representation in the context of quantum mechanics.
Matthew Malencia is a robotics researcher, an AI educator, and a science policy advocate. He is pursuing a Ph.D. in Electrical and Systems Engineering at the University of Pennsylvania with advisors Dr. Vijay Kumar and Dr. George Pappas, and he is a visiting researcher at the University of Cambridge with Dr. Amanda Prorok. His research focuses on fairness and diversity on robot teams. Matthew is the co-director of AI4ALL@GRASP, a summer program that teaches Philadelphia area high school students the fundamentals of artificial intelligence and robots. Lastly, Matthew works with the Science Policy & Diplomacy Group at the University of Pennsylvania on AI ethics and policy. He has written multiple AI memos, engaged with policymakers on AI topics, and delivered an intervention on the floor of the United Nations during a science and technology forum.
Divya Jain is a Ph.D. student at the Center for Injury Research and Prevention at the Children’s Hospital of Philadelphia and the University of Pennsylvania and is co-advised by Dr. Kristy Arbogast and Dr. Catherine McDonald. Her doctoral work centers on objective methods for diagnosing and monitoring recovery from concussion in adolescents, with a focus on determining when adolescents should return to driving motor vehicles after their injury. Divya holds a bachelor's degree in bioengineering from the University of Maryland, College Park and is an HHMI-NIBIB Interfaces Scholar and a Dwight D. Eisenhower Transportation Fellow.
Walker Gosrich is a Ph.D. Candidate studying robotics in the GRASP Lab at the University of Pennsylvania. He is an NSF Graduate Fellow working under Dr. Mark Yim, and researches planning and control for teams of robots using tools such as machine learning and graph theory. He is the Policy Chair of the Penn Science Policy and Diplomacy Group. His policy interests center on how policy affects the development and implementation of new robotics and AI technologies. Walker received his Bachelors in Mechanical Engineering from the University at Buffalo in 2018.
Val Bromberg is a second-year undergraduate student majoring in Biology, with a concentration in Mechanisms of Disease, and minoring in Chemistry at the University of Pennsylvania’s College of Arts and Sciences. She works with Dr. Harvey Friedman in the Friedman lab, a lab which aims to provide protection from Herpes simplex viruses through the creation of a vaccine utilizing mRNA technology. Additionally, she works with a research group led by Dr. Brendan Kelly and Dr. Michael David to assess outcomes in COVID-19 patients who were given empiric antibiotics and/or developed bacterial superinfections throughout their hospital admissions.
Sonia Roberts is a Ph.D. student in Electrical and Systems Engineering at the University of Pennsylvania. She works with Prof. Dan Koditschek in Kod*Lab, a legged robotics research group in the General Robotics, Automation, Sensing, and Perception (GRASP) Lab. Her Ph.D. work focuses on locomotion on soft, fragile substrates like sand, and how robots can respond to these difficult environments without needing complex internal models of them. Sonia's undergraduate degree is from Vassar College where she studied Cognitive Science, and she spent two years working as a research technician at the Howard Hughes Medical Institute's Janelia Farm Research Campus before coming to Penn.
Mathieu Ouellet is a Ph.D. student in Electrical and Systems Engineering at the University of Pennsylvania. He works with Prof. Danielle Bassett in the Complex Systems Lab UPenn, a multidisciplinary laboratory interested in the many facets of Complex Systems. He also works with Prof. Lee Bassett in the Quantum Engineering Lab @Upenn, a research group focused on understanding and controlling nanoscale quantum properties in semiconductor materials. His Ph.D. work focuses on understanding the properties of systems of multiple interacting components. Mathieu has a bachelor’s degree in computer science and physics from the University of Quebec. He also completed a master’s degree in applied mathematics, where he studied supersymmetry and the power spectral parameter representation in the context of quantum mechanics.
Matthew Malencia is a robotics researcher, an AI educator, and a science policy advocate. He is pursuing a Ph.D. in Electrical and Systems Engineering at the University of Pennsylvania with advisors Dr. Vijay Kumar and Dr. George Pappas, and he is a visiting researcher at the University of Cambridge with Dr. Amanda Prorok. His research focuses on fairness and diversity on robot teams. Matthew is the co-director of AI4ALL@GRASP, a summer program that teaches Philadelphia area high school students the fundamentals of artificial intelligence and robots. Lastly, Matthew works with the Science Policy & Diplomacy Group at the University of Pennsylvania on AI ethics and policy. He has written multiple AI memos, engaged with policymakers on AI topics, and delivered an intervention on the floor of the United Nations during a science and technology forum.
Divya Jain is a Ph.D. student at the Center for Injury Research and Prevention at the Children’s Hospital of Philadelphia and the University of Pennsylvania and is co-advised by Dr. Kristy Arbogast and Dr. Catherine McDonald. Her doctoral work centers on objective methods for diagnosing and monitoring recovery from concussion in adolescents, with a focus on determining when adolescents should return to driving motor vehicles after their injury. Divya holds a bachelor's degree in bioengineering from the University of Maryland, College Park and is an HHMI-NIBIB Interfaces Scholar and a Dwight D. Eisenhower Transportation Fellow.
Walker Gosrich is a Ph.D. Candidate studying robotics in the GRASP Lab at the University of Pennsylvania. He is an NSF Graduate Fellow working under Dr. Mark Yim, and researches planning and control for teams of robots using tools such as machine learning and graph theory. He is the Policy Chair of the Penn Science Policy and Diplomacy Group. His policy interests center on how policy affects the development and implementation of new robotics and AI technologies. Walker received his Bachelors in Mechanical Engineering from the University at Buffalo in 2018.
Val Bromberg is a second-year undergraduate student majoring in Biology, with a concentration in Mechanisms of Disease, and minoring in Chemistry at the University of Pennsylvania’s College of Arts and Sciences. She works with Dr. Harvey Friedman in the Friedman lab, a lab which aims to provide protection from Herpes simplex viruses through the creation of a vaccine utilizing mRNA technology. Additionally, she works with a research group led by Dr. Brendan Kelly and Dr. Michael David to assess outcomes in COVID-19 patients who were given empiric antibiotics and/or developed bacterial superinfections throughout their hospital admissions.
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ISSN 2372-2193
ISSN 2372-2193