Review a lender’s use of a model in credit decisions
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- List the decision points, the data fields and the adverse-action notices in the file the lawyer supplies, and flag where a reason is missing. Do not write the notice.
- What the lawyer must review
- The Equal Credit Opportunity Act makes it unlawful for a creditor to discriminate in any aspect of a credit transaction on the basis of race, color, religion, national origin, sex, marital status or age (if the applicant has capacity to contract), because income comes from a public assistance program, or because the applicant exercised a right under the Consumer Credit Protection Act (15 U.S.C. § 1691(a)). An applicant against whom adverse action is taken is entitled to a statement of the specific reasons (§ 1691(d)). You decide whether the model and the notice meet that statute. Opinion 512: do not put applicant files into a public tool.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Potential support includes identifying points for review. Confirm the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Review operative clauses in the complete document, including definitions, cross-references, schedules and inconsistencies with the instructions.
- Confirm instructions and personal circumstances through appropriate direct engagement. Have the responsible lawyer assess safety, capacity or vulnerability concerns and escalation.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.