CFPB Circulars 2022-03 / 2023-03 / 2024-04 + Reg B § 1002.9(b)(2) compliance, without the 0.5–1 FTE. AttestProto signs each adverse-action decision and auto-maps the citation, 30-day notice, and human-review pathway.
Reg B § 1002.9(b)(2) requires the principal reasons for adverse action. "AI denied" doesn't qualify. CFPB has said so three circulars in a row.
Section 1002.9(a) requires written notice within 30 days. Mapping the AI decision to a human-reviewable record is hand-rolled at most fintechs.
Add Colorado AI Act, GDPR Article 22 (EU customers), state UDAP analogues. Your team rebuilds the same compliance bundle four ways.
No install, no account. The keypair is generated client-side and never leaves this page. Same code path as the production CLI.
Every signed adverse-action attestation can render a customer-facing FCRA § 1681m + ECOA Reg B § 1002.9(b)(2) notice — specific reasons, ECOA rights statement, FCRA consumer-reporting-agency disclosure, all in the language CFPB examiners expect. Plain text or Markdown. One CLI flag.
Pulls «specific reasons» from attestation.output.factors directly — no per-notice copywriting. Markdown output drops into your audit bundle unchanged.
Most AI lending operators discover too late that their cyber, generic E&O, or D&O policy is silent or excludes algorithmic discrimination. Pick your current policy stack — see how it actually responds to the eight liability scenarios CFPB, state AGs, and class-action plaintiffs are filing in 2024-2026. Underwriters increasingly require per-decision attestation evidence on renewal.
E&O with explicit AI / algorithmic decision-making endorsement (Munich Re, Vouch, Coalition specialty)
| Liability scenario | Coverage under E&O — AI/algorithmic endorsement | Statute / case basis |
|---|---|---|
| FCRA class action — bad reason codes | ●Covered | 15 U.S.C. § 1681m + § 1681n / § 1681o |
| ECOA class action — adverse action notice failure | ●Covered | 15 U.S.C. § 1691 / Reg B § 1002.9 |
| CFPB enforcement — explainability deficit | ◐Partial | Circular 2022-03 + UDAAP |
| State AG action (NY DFS, CO Atty Gen, CA AG) | ●Covered | NY 23 NYCRR 500 / CO AI Act / CCPA |
| EU AI Act high-risk fine (incoming) | ◐Partial | Regulation (EU) 2024/1689 Art. 99 |
| PII breach in attestation logs | ○Silent (assume excluded) | GLBA Safeguards / state breach laws |
| Sub-vendor (LLM provider) liability spillover | ◐Partial | CFPB 2024-04 + service-provider doctrine |
| Plaintiff alleges no adverse action notice ever sent | ●Covered | FCRA § 1681m(a) + private right of action |
Not legal or insurance advice. Coverage varies by carrier, jurisdiction, endorsement, and policy form. Validate with your broker before relying.
Take this matrix to your broker before renewal. If the broker can't answer in writing whether the policy responds to FCRA / ECOA / CFPB claims arising from algorithmic decisions, you don't have coverage — you have hope.
Pick your deployment context. Get back a context-tailored DD questionnaire mapped to FCRA, ECOA, NYC LL144, CO AI Act, EU AI Act, GDPR Art. 22, and CFPB Circulars. Each question includes the why, the citation, and the evidence to demand. Copy as markdown or download — bring it to your next vendor pitch and watch how many can't answer.
Compiled from FCRA, ECOA, NYC LL144, CO AI Act, EU AI Act, GDPR Art. 22, CFPB Circulars 2022-03 / 2023-03 / 2024-04, OCC Bulletin 2021-39, NY DFS 23 NYCRR 500. Not legal advice — validate scope with counsel for your jurisdiction.
Run inside your existing compliance perimeter. No vendor SaaS round-trip with PII.
Hash-chain integrity. Decision history is tamper-evident; regulator examination is straightforward.
0.5-1 FTE saved at fully-loaded $150-200k vs $25-50k/year licence.
We'll demo the auto-mapping fire on a sample lending attestation. If it doesn't fit your stack, no follow-up.