Algorithmic fairness in lending today relies on group fairness metrics for monitoring statistical parity across protected groups. This approach is vulnerable to subgroup discrimination by proxy, carrying significant risks of legal and reputational damage for lenders and blatantly unfair outcomes for borrowers. Practical challenges arise from the many possible combinations and subsets of protected groups. We motivate this problem against the backdrop of historical and residual racism in the United States polluting all available training data and raising public sensitivity to algorithmic bias. We review the current regulatory compliance protocols for fairness in lending and discuss their limitations relative to the contributions state-of-the-art fairness methods may afford. We propose a solution for addressing subgroup discrimination, while adhering to existing group fairness requirements, from recent developments in individual fairness methods and corresponding fair metric learning algorithms.