You Can't Ask Their Race. Regulators Expect You to Know Anyway.
When self-reported race data is unavailable, most compliance tools rely on a widely-used proxy method that systematically understates racial disparities — creating exam and litigation exposure institutions don't see coming until it's tested. CREST replaces that guess with a measurement built to hold up under regulatory exam and in court.
Getting this wrong is expensive — and it's not hypothetical
Someone has to estimate race when it isn't self-reported — for HMDA fair lending analysis, a CRA exam, or a discrimination claim in litigation. If that estimate is wrong in a way that systematically favors the institution, examiners and opposing counsel will eventually find it. “Our vendor's tool produced the number” is not a defense that holds up once it's actually tested — and the tools built to make this simple were never built to survive that test.
Where PPP forgiveness went — and where it didn't, by neighborhood.
Within five miles of a community bank — and the loan went elsewhere anyway.
During the Paycheck Protection Program, minority-owned businesses disproportionately borrowed through a nationwide platform channel that forgave loans at markedly lower rates than branch-based community banks. Most were not remote — they sat inside the everyday footprint of a community bank that, on its own record, forgave at a far higher rate.
Chalavadi, Leitch & Pastor. Decomposes the forgiveness gap into within-lender and between-lender components, and traces the between-lender share to sorting into a nationwide platform channel — not to physical distance from a community bank.
Read the PaperThe compliance layer, and the engine beneath it
CREST produces the defensible disparity estimate. STRATA is the validated inference engine that feeds it — available on its own as a hosted API or a private no-egress deployment.
CREST quantifies how much legacy proxy methods understate discrimination — producing defensible disparity estimates for compliance self-testing, regulatory exam support, and litigation.
- Financial institutions for fair lending self-testing and exam defense
- Insurers meeting NAIC proxy-testing mandates and Colorado's SB 26-189 transparency law (effective Jan. 2027)
- Applicable across fair lending, employment, insurance, housing, healthcare, and criminal justice
- Enterprise — includes full STRATA imputation$100,000 / yr
- Standalone — litigation & consulting$15,000 / matter
The validated ML inference engine beneath CREST. LSTM + geographic → XGBoost pipeline, validated independently on a 981,000-record HMDA holdout and a 1.07M-record PPP external validation — two separate validations on two separate populations; neither substitutes for or confirms the other. Available as a hosted API or a private no-egress deployment for regulated institutions.
- Free tierto 100K rows/mo
- Starter$1.00 / 1K rows
- Growth — 1M–10M$0.75 / 1K rows
- Scale — 10M+$0.50 / 1K rows
- AWS Marketplace$0.03 / 1K rows
- STRATA Premium — no-egress$20,000–$45,000 / yr
Why existing tools get this wrong
BISG's errors are SES-correlated, not random
Minorities in wealthier areas are misclassified as White; Whites in poorer areas are misclassified as non-White. The result: measured Black–White approval disparities are understated by approximately 43% in small-business lending (Greenwald et al., J. Financial Economics 157 (2024), 103857). CREST corrects for this structure — not just the headline accuracy number.
Outperforms the alternatives on the same ground truth
STRATA outperforms BISG, BIFSG, ZRP, and all major open-source alternatives on HMDA and PPP ground truth — but the durable moat is the compliance layer, not the benchmark.
CREST's bias simulation and disparity estimation methodology is patent-pending (application 64/067,906).
Built from federal-grade methodology
The STRATA pipeline grew out of SSA race/ethnicity modeling work. The same rigor that supports federal agency analysis — reproducible, versioned, auditable — is now available as a commercial API and compliance platform.
Two deployment modes for every buyer
Hosted API for researchers, fintechs, and advocacy organizations. Private AWS container for banks, insurers, and mortgage lenders where PII cannot leave the institution's environment. Data never leaves your infrastructure in the Premium tier.
Published and peer-reviewable
Ready to talk?
Whether you're a compliance team preparing for exam, counsel quantifying discrimination harm, an insurer facing proxy-testing mandates, or a researcher — we'd like to hear from you.