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 baseline vs recent underwriting-risk-score distribution comparison
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

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:

  1. 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.
  2. The right tail grows. More H3 applications score above the decline / non-QM threshold.
  3. 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:

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 →

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