I have NO idea! I know some financial institutions advertise (and sponsor) really big sport events with viewership that ranges in the 10s of millions. It is pos

I have NO idea! I know some financial institutions advertise (and sponsor) really big sport events with viewership that ranges in the 10s of millions. It is possible there is a distinction between "We are a company, remember our logo" and "we are a company, use our credit card". I do know that proxy variables are just as bad as discrimination variables. So, if I approve based on zip code, and zip code is highly correlated with a protected class - that is not legal (think: red lining practices). But it gets tricky. If black people use pay day lenders, can I decline because I see pay day lenders on your credit history? Not directly, but I can decline if I see lots of "open lines of credit" or "delinquent loans". In my area, we also go back over our variables to look for "accidentally discrimination" e.g. no one would expect that: high income, large down payment, expensive car loan, commission based income would correlate with a protected class - but maybe it does, so we better check!