Regulation — housing-specific
FCRA (15 USC 1681) — AI adverse-action notice + credit-file accuracy
The Fair Credit Reporting Act sits under ECOA's adverse-action requirements. When an AI declines a mortgage application using consumer-report data, FCRA imposes its own adverse-action notice + accuracy + dispute-handling duties — separate from Reg B, and separately enforceable.
What the regulation actually says
"If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall — (A) provide oral, written, or electronic notice of the adverse action to the consumer; (B) provide to the consumer written or electronic disclosure — (i) of a numerical credit score … used by such person in taking any adverse action …"
15 U.S.C. §1681m(a) — FCRA adverse-action notice
What this means in plain English
Three duties layered on top of Reg B when a consumer report drives the AI decision:
- Adverse-action notice includes the score used. Numerical credit score disclosure is required, not optional.
- Accuracy duty runs through the whole chain. Any party pushing consumer-report data into the AI has accuracy duties. Any party pulling AI outputs back onto the file has record-keeping duties.
- Dispute-handling process must be operational. Applicants can dispute the underlying data. The lender cannot hide behind AI opacity when the dispute lands.
What triggers the exposure in the sample
Every H3 decline in the drift window generates an FCRA-covered adverse-action notice. If the AI's decision was driven by a drifted model state rather than by the credit-report data itself, the notice's score attribution is questionable. Dispute-response is harder without model version + input snapshot + decision-hash retention.
What the $499 Snapshot shows against this rule
- Decision-hash record per sampled decision — the "what drove this notice" record
- Model-version pinning — the "which model version scored this file" record
- Retention discipline dated — the dispute-response readiness record
- Independent-verifier declaration — the accuracy-duty-was-monitored record
$499 Snapshot. 3 business days.
Independent-verifier determination + adverse-action traceability record + 3 fix-first items.
Buy $499
Snapshot credit applies to Baseline ($2,500) or Enterprise Attestation ($35-55K) upgrade within 30 days.