Regulation — housing-specific

HMDA (12 USC 2801) — AI-decision reporting + LAR reproducibility

The Home Mortgage Disclosure Act is the reporting spine of fair-lending supervision. Each Loan Application Register (LAR) row must trace to a reproducible underwriting decision. When AI drives the routing, every LAR row's action-taken code is only as defensible as the model version and inputs that produced it.

What the regulation actually says

"The purpose of this chapter is to provide the citizens and public officials of the United States with sufficient information to enable them to determine whether depository institutions are filling their obligations to serve the housing needs of the communities and neighborhoods in which they are located …" 12 U.S.C. §2801(b) — the underlying statute

"A financial institution shall maintain records that are sufficient to enable the appropriate agency to determine whether the institution has complied with the requirements of this part." 12 CFR 1003.5(e) — Regulation C, record-retention obligation

What this means in plain English

Two duties that intersect directly with AI:

Every LAR row must be accurate. Action taken, reasons for denial, applicant demographic data. Errors are individually penalized and pattern-of-error triggers supervisory action.
Every reported row must be reproducible. If a regulator asks how a particular application was decided, the lender must be able to show model version, inputs, and output that produced the reported action code.

What triggers the exposure in the sample

~740 H3 applications routed to decline / non-QM during the 45-day drift window. Each becomes a LAR row with action-taken code that must trace back to a defensible model state. Without model-version pinning + input snapshot + decision-hash binding, those LAR rows are reported into HMDA without the record of what actually produced them.

What the $499 Snapshot shows against this rule

Model version pinning per decision (mock: mortgage-underwriter-v4.7.2) — the reproducibility record
Decision-hash binding — tampering-detectable link between input and reported outcome
Retention discipline per HMDA Sec 304 — the record-retention record
Counterparty-question rehearsal on 5 sample Day-47 decisions — the LAR-audit dry run

See the 5-decision reproducibility drill →

How does this help me?

HMDA errors compound: a single reporting round with pattern-of-error triggers a supervisory follow-up cycle that costs multiples of proactive record discipline.

Read: HMDA -- what LAR reproducibility saves you at the next filing →

$499 Snapshot. 3 business days.

Independent-verifier determination + reproducibility-drill record + 3 fix-first items.

Buy $499

Snapshot credit applies to Baseline ($2,500) or Enterprise Attestation ($35-55K) upgrade within 30 days.