Deep dive — methodology

How the A / B / C determination is derived

Every $499 Snapshot lands on exactly one overall determination. Not a color code, not a health score — an A / B / C determination tied to attestation stance. Here is exactly how it is derived.

The three categories

CategoryMeaningAttestation stance
A No high-severity drift events. No group-differential signal. Baseline vs recent distributions match within threshold. Sufficient for attestation. Signed evidence available on file.
B Medium-severity drift or single-event high-severity without repeated group-differential signal. Aggregate metrics stable. Conditional. Named remediation + re-audit within defined window supports attestation.
C Multiple high-severity drift events OR repeated group-differential signal fired across the audit period. Insufficient. Bank should not represent the AI as SR 11-7-compliant or fair-lending-defensible until remediation completes.

The evidence chain

  1. Sensor thresholds active during the audit:
    • Mean-shift threshold: 1.5 standard deviations from baseline
    • Variance-ratio threshold: 1.5x baseline
    • KL-divergence threshold: 0.2
    • Group adverse-impact differential threshold: 12% shift across borrower groups
  2. Event classification:
    • Any single-threshold cross → medium-severity event
    • KL-divergence > 0.5 OR group-differential signal → high-severity event
  3. Category assignment:
    • 0 high-severity + 0 group-differential → A
    • 1-2 high-severity, no repeated group-differential signal → B
    • ≥ 3 high-severity OR repeated group-differential signal → C

Why this sample lands on C

14 high-severity drift events + B3 KL-divergence signal repeated on Days 44, 51, 58, 65, 72, 79, and 86. Either condition alone is sufficient for C. Both are present. The determination is not marginal.

Why the A/B/C structure matters

Continuous-scale scores (0-100 dashboard, red/yellow/green tri-lights, "health-score" percentages) push operators toward "just above the threshold" gaming behavior. A / B / C determinations force a single stance question:

Would you sign the SR 11-7 attestation as-is today? A / B / C answers the question that regulators, boards, and audit committees actually ask — instead of the question the vendor's dashboard prefers.

How does this help me?

Knowing your category BEFORE the OCC exam / CFPB inquiry / board risk-committee agenda item lands is the whole value of the $499 discipline.

Read: The value of knowing your category first →

$499 Snapshot. 3 business days.

Get your bank's Category A / B / C determination on your actual AI credit-underwriting surface — before someone else's question forces the answer.

Buy $499