Deep dive — chart 2
Chart 2 — H3 baseline vs recent distribution
The how. Where Chart 1 shows when the H3 line diverged, this chart shows how the H3 underwriting-risk-score distribution shape shifted. Mass moved right, into the decline / non-QM lane.
H3 underwriting-risk-score distribution — baseline (blue) vs recent (orange). Mass shifted right, past the decline / non-QM lane threshold at score 67.
What you are looking at
- X-axis: underwriting-risk-score (0 to 100)
- Y-axis: density of applications at that score for H3
- Blue distribution: baseline window (first 30 days), what H3 scoring normally looks like
- Orange distribution: recent window (last 30 days), what H3 scoring looked like at Snapshot time
- Vertical line at score 67: threshold for routing to decline / non-QM lane
What the shape shift means
The orange distribution's mass has moved right compared to the blue distribution. Three things are happening at the same time:
- The peak (mode) moves up. The most common H3 score used to sit in the manual-review band; now it sits at the edge of decline.
- The right tail grows. More H3 applications score above the decline / non-QM threshold.
- The left tail shrinks. Fewer H3 applications score in the auto-approve range.
Underwriting translation: the AI now systematically scores near-prime H3 files as higher risk than baseline. The score does not distinguish between "near-prime H3 with real credit repair" and "sub-prime H3 with genuine risk." The distribution shape drift is the mathematical fingerprint of that underwriting failure mode.
What KL-divergence quantifies
Kullback-Leibler divergence measures how different one distribution is from another. Values:
- KL < 0.05: the same distribution (random noise)
- KL 0.05-0.2: mild shift, monitor
- KL 0.2-0.5: significant shape shift, flag as medium event
- KL 0.5-1.0: substantial shape shift, high-severity event
- KL > 1.0: distributions barely overlap — the population the AI is scoring is behaviorally different from the population it was trained on
The sample's H3 KL-divergence hit 0.833 on Day 44 and 0.963 on Day 65. Well above threshold, and it stayed there. H5 also fired on Days 30, 37, and 79.
The underwriting + regulatory read
Underwriting read: the AI has drifted out of calibration for near-prime H3 files. Manual senior-underwriter re-review should apply until retraining + validation.
Regulatory read: the shape shift is precisely the kind of "measurable drift on a specific applicant class" that Fair Housing Act disparate-impact analysis, ECOA effects-testing, CFPB Circular 2022-03 reason-code review, and SR 11-7 ongoing-monitoring all expect the operator to detect and act on.
The next chart
The baseline-vs-recent chart shows how the H3 distribution shifted. The lane-rate chart shows the operational consequence: which lane are H3 files getting routed to now vs baseline.
Chart 3 — lane rate per applicant group →
$499 Snapshot. 3 business days.
Same shape-analysis for your lender's actual AI surface + full analysis report.
Buy $499