Deep dive — methodology
Counterparty-question rehearsal — the 5-decision reproducibility drill
Every $499 Snapshot samples five AI-driven credit decisions from a target-day and reproduces them defensibly. Not because you need them all today — because the discipline of reproducing five proves the discipline could reproduce any of them tomorrow.
The prompt the rehearsal answers
"Reproduce this AI-generated credit-underwriting decision from Day 47, including the applicant's stated purpose, credit-bureau snapshot at decision-time, model version, underwriting-risk-score, and lane routed — as a defensible record we can produce for CFPB supervisory examination, OCC / Fed / FDIC MRA response, state AG fair-lending inquiry, or class-cert opposition."
The counterparty question — identical shape whether it comes from CFPB, examiner, plaintiff, or carrier
Sample credit-underwriting decisions from Day 47
| Application ID | Score | Lane | Model version | Decision hash |
|---|
| APP-002534 | 73.88 | Decline / Secondary Market | credit-underwriter-v6.1.4 | cuw-002534 |
| APP-002533 | 43.56 | Manual Review / Price-Up | credit-underwriter-v6.1.4 | cuw-002533 |
| APP-002532 | 52.40 | Manual Review / Price-Up | credit-underwriter-v6.1.4 | cuw-002532 |
| APP-002531 | 62.04 | Manual Review / Price-Up | credit-underwriter-v6.1.4 | cuw-002531 |
| APP-002525 | 45.75 | Manual Review / Price-Up | credit-underwriter-v6.1.4 | cuw-002525 |
What "defensibly reproduced" means
- Model version pinned. Not "the current model" — the exact model version deployed at decision-time.
- Input snapshot bound. Stated purpose + credit-bureau snapshot + DTI + requested amount exactly as they were when the AI scored the application.
- Decision hash bound. Cryptographic hash tying the input to the output — makes tampering detectable.
- Retention pipeline independent. The retention system that holds the decision records is not the production model itself — independence of the record from the actor being recorded.
What the rehearsal proves
All 5 sampled Day-47 credit-underwriting decisions reproduced with defensible-records match. Model version pinned, decision hash cryptographically bound, input data retained via decision-provenance record. If CFPB / examiner / plaintiff / carrier requests any of the ~4,969 applications in the audit period, the same reproduction procedure applies.
Retention horizon
- FCRA 15 USC 1681m: 25-month minimum post-adverse-action
- Reg B 12 CFR 1002.12(b): 25-month application retention
- SR 11-7 model documentation: typically 7+ years for federally-regulated depository institutions
- Litigation hold: preserves through matter conclusion, may extend the original horizon
The rehearsal record is not a one-time exhibit — it is proof that the retention discipline is operational.
Why 5, not 500
Reproducing 500 decisions on request is a discovery-response exercise, appropriately triggered by a specific legal or regulatory process. Reproducing 5 sample decisions at Snapshot time is a discipline-test: it validates that the retention pipeline works, without exhausting the audit budget on record production nobody has asked for yet.
$499 Snapshot. 3 business days.
Same 5-decision reproducibility drill on your bank's actual AI credit-underwriting surface + counterparty-question rehearsal record.
Buy $499