The declaration verbatim
"I, Kevin Luddy, as principal of contrarianAI LLC, personally attest that:
1. contrarianAI is not an employee, contractor, equity holder, or vendor of the audited lender or any of its mortgage-tech vendors (ICE, Blend, Rocket Logic, Zest AI, Upstart, Stavvy, Encompass, Byte, Calyx, LendingQB, or any similar).
2. Assessment tools (distributional-shape sensor, retrieval-auditor, tool-call-grader, prompt-drift-sensor, predictor-corrector, router-drift-sensor) use model families and evaluation methods distinct from those in production at the audited lender.
3. This Snapshot is based on the data-sample submitted by the buyer. Changes to the audited lender's infrastructure after the Snapshot date are outside this Snapshot's scope.
4. Underlying audit evidence is retained for the Snapshot horizon and will be made available for legitimate regulatory / audit / counterparty inquiry (CFPB, OCC, FRB, FDIC, NCUA, HUD, DOJ, state banking department, GSE, or counterparty investor) with appropriate legal process."
Sample declaration — signed Kevin Luddy, Principal, contrarianAI LLC, 2026-07-22
Why "personally attest" matters
Kevin Luddy's name is on the signature. Not "contrarianAI LLC." Not "the audit team." A named principal, standing behind the statement. That is how attestations that survive legal challenge are structured — a named person, addressable, cross-examinable.
The Big-4 consultancies do this at $200K-$1M+ per fair-lending-audit engagement. The $499 Snapshot does the same discipline at 5-10% of the price by scoping tightly to one AI surface + producing one determination + retaining evidence.
What "control plane" means
A control plane in systems engineering is the layer that observes and governs another layer's behavior, from outside that layer. Applied here:
- The AI vendor's own monitoring is inside the vendor's plane. Vendor cannot credibly grade its own homework.
- The lender's IT monitoring is inside the lender's plane. Same principle.
- The lender's Model Risk Management group is closer — but if it uses the same telemetry pipeline as production, it inherits the same blind spots.
- An independent verifier — distinct entity, distinct methodology, distinct retention — is outside all of them. That is the control plane.
"We use our LOS vendor's fair-lending module" is the modal answer regulators reject. The Snapshot exists so that a defensible answer — independent verifier, signed declaration, retained evidence — can be produced at $499.