Wells Fargo, Zest AI & the Pitfalls of 'Intentional Inclusion’

The term "intentional inclusion" has gained traction in fintech circles — often paired with bold mission statements and DEI commitments. But what happens when the intent doesn’t align with outcomes?

When inclusion becomes a brand tool rather than a rigorous design principle? Two powerful case studies — Wells Fargo and Zest AI — show us how even well-meaning efforts can falter without clear accountability, transparency, and a systems-based approach.

Wells Fargo: When Apologies Aren’t Enough

Wells Fargo has made repeated public commitments to advancing racial equity, pledging billions to support Black-owned businesses and communities. Yet these pledges have been overshadowed by persistent discrimination scandals, including:

• A 2022 report showing that nearly half of Black mortgage applicants were denied by Wells Fargo, despite comparable credit profiles to white peers.

• A long history of redlining and discriminatory lending, resulting in class-action lawsuits and settlements totaling hundreds of millions.

• PR-first initiatives — like grants and sponsorships — without measurable change in underwriting outcomes or internal accountability structures.

The lesson? When inclusion is driven by marketing goals rather than system redesign, it fails the communities it's meant to serve. Trust isn’t built with pledges; it’s built with policies, transparency, and action.

Zest AI: An Algorithm with Promise — and Risk

Zest AI was founded on the idea that artificial intelligence could eliminate bias in lending. Its pitch? Replace human prejudice with machine learning, using alternative data to expand credit access.

On the surface, this is a compelling equity play. But there are caveats:

• AI models are only as unbiased as their training data. If historical lending decisions reflect systemic racism, algorithms trained on that data can replicate those patterns — faster and at scale.

• Opaque decision-making creates new forms of exclusion. If consumers are denied credit by a machine, but no one can explain why, it reinforces the very distrust that fintechs are trying to overcome.

This is exactly the concern regulators have begun to raise. In March 2022, CFPB Director Rohit Chopra delivered pointed remarks warning that many so-called “fairness tools” in lending were little more than automated discrimination cloaked in tech language:

“We must ensure that models marketed as ‘fairness tools’ aren’t simply repackaging discrimination in a more automated form. We are paying close attention to vendors who claim to remove bias but cannot fully explain how their tools work.” — CFPB Remarks, March 2022

Though Zest AI was not mentioned by name, outlets like American Banker and Protocol specifically connected these concerns to Zest’s business model — which centers on proprietary machine learning tools that many lenders cannot fully interpret or explain under ECOA compliance standards.

Following this increased scrutiny, Zest AI has implemented explainability tools and compliance protocols to mitigate the risks that come with AI-driven credit decisions.

Zest’s story is a cautionary one: even well-intended fintechs can replicate harm if oversight, transparency, and auditability aren’t present from the start. Responsible innovation requires more than good intentions — it demands community accountability and continuous course correction.

The Real Work of Inclusion

True inclusion isn’t about sprinkling diversity into a product. It’s about reimagining systems to serve those they’ve historically excluded. That means:

• Redesigning risk models with community-informed metrics, not just predictive analytics.

• Investing in human accountability alongside technology.

• Being honest about where your systems fall short — and inviting correction.

Conclusion

If fintechs want to do more than echo the right language, they must build the right structures. Wells Fargo shows us the cost of performative inclusion. Zest AI reminds us that innovation without accountability can replicate harm.

At Blaze Group, we guide financial institutions and fintechs through the hard, necessary work of designing systems that serve equitably — on purpose and by design.

Let’s move beyond intent. Let’s build inclusive finance that works.

Learn more at blazegroup.io or explore our fintech training and consulting at blazegroup.io/fintech.