---
title: "Review a lender’s use of a model in credit decisions"
url: "https://ailawframework.com/practice/banking-and-finance/review-a-lender-s-use-of-ai-in-credit-decisions/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A3-B8-1-US"
practice_area: "Banking & Finance (Lending, Securities, Project Finance)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Review a lender’s use of a model in credit decisions

> 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.

Canonical page: https://ailawframework.com/practice/banking-and-finance/review-a-lender-s-use-of-ai-in-credit-decisions/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Banking & Finance (Lending, Securities, Project Finance)](https://ailawframework.com/practice/banking-and-finance.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| 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 | United States |
| Applies to | [Review a lender's use of AI in credit decisions](https://ailawframework.com/practice/banking-and-finance/review-a-lender-s-use-of-ai-in-credit-decisions.md) |

## Checking plan

- What the AI does: 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.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Adverse action includes a denial, a revocation, a change in terms, or a refusal to grant credit substantially as requested. Read § 1691(d) for the exceptions.
- Do not treat a model score as a specific reason.

## Sources

- [15 U.S.C. § 1691, Equal Credit Opportunity Act](https://www.law.cornell.edu/uscode/text/15/1691) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)
- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*