While we found no fair lending violations, our inquiry stands as a reminder of disparities in access to credit that continue nearly 50 years after the passage of the Equal Credit Opportunity Act (ECOA). [...] the Department concluded, deficiencies in customer service and a perceived lack of transparency undermined consumer trust in fair credit decisions.
In November 2019 a software developer posted that Apple Card had given him a credit limit twenty times his wife's, on joint returns and with her holding the higher credit score, and that nobody at either company could say why. New York's financial regulator opened an investigation and worked through underwriting data for around 400,000 applicants. Its 2021 finding was that men and women with similar credit characteristics got similar outcomes and that every decision it examined was explainable and lawful. The case is here because of the gap it exposes rather than a violation it found: a decision can be lawful, explainable to a regulator with the data, and still unexplainable to the person it was made about, and eighteen months of reputational damage happened in that gap.