Governance & Program Info
Dynamic Pricing & Real-Time Underwriting — Governance
Cross-builder institution context and per-item ownership, due dates, status, and next actions for the governance-relevant checklist items in this builder.
Institution context
Program info
Applies across every builder in the app. Stored locally; nothing leaves the browser.
Checklist governance
Items (0 of 16 marked complete)
Annotate ownership, due date, status, and next action. Items on the left come from the builder's governance / compliance phases.
05 · Governance & Compliance
Complete SR 11-7 model documentation package
Purpose, data lineage, assumptions, limitations, known failure modes, validation results — all seven SR 11-7 documentation elements.
05 · Governance & Compliance
Independent model validation
Second-line or external team validates model logic, data, assumptions, and performance claims. Must be independent of model development.
05 · Governance & Compliance
Ongoing outcome-comparison monitoring
Monthly / quarterly comparison of predicted vs. actual default rates per credit band — required by SR 11-7 as continuous validation.
05 · Governance & Compliance
Change management and model versioning
Who approves model updates, what testing is required, how are changes versioned and rolled back, what is the audit trail.
05 · Governance & Compliance
Adverse action notice generation within 30 days
ECOA Reg B §1002.9 requires specific principal reasons for denial, delivered within 30 days of decision.
05 · Governance & Compliance
Map SHAP attribution to adverse-action reason codes
Deterministic mapping from top-k SHAP features to regulator-readable reason codes; reviewed by compliance.
05 · Governance & Compliance
Reg Z / TILA disclosure integration
APR, finance charges, payment schedule, and BNPL-specific disclosures (post-May 2024 CFPB interpretive rule) delivered at offer time.
05 · Governance & Compliance
FCRA pre-adverse-action notice
If bureau data was material to the denial, FCRA requires pre-adverse-action notice giving the consumer the opportunity to dispute.
05 · Governance & Compliance
CFPB 1033 consumer-consent and data-access compliance
Consumer right to access, share, and revoke bank transaction data — must be built into the data flow.
05 · Governance & Compliance
Data minimization for 1033-sourced data
Only the features needed for the decision are retained; raw transactions are purged or anonymized per policy.
05 · Governance & Compliance
EU AI Act Annex III high-risk conformity
Risk management system, data governance, technical documentation, automatic logging, transparency, human oversight, accuracy/robustness — Articles 9–15.
05 · Governance & Compliance
Colorado AI Act (SB205) compliance program
Consequential decisioning AI obligations effective February 2026 — risk management, impact assessment, algorithmic discrimination duty.
05 · Governance & Compliance
NYC Local Law 144 analogous review (as precedent)
NYC's AEDT law (employment) is the closest-enforced analog for what consequential-decisioning AI laws look like in practice — useful precedent even though it does not directly apply to lending.
05 · Governance & Compliance
Track NAIC AI Model Bulletin adoption state-by-state
For insurance dynamic pricing — 23 US states + DC had adopted the NAIC model bulletin as of August 2025; adoption continues to expand.
05 · Governance & Compliance
Board-level AI governance reporting
Approval rate, loss rate, disparate-impact ratios, model-drift metrics should appear in board risk reporting — not only ops dashboards.
05 · Governance & Compliance
HMDA Regulation C reporting integration
For mortgage products — HMDA LAR reporting must integrate with the AI decisioning output; HMDA is the primary evidence base for disparate-impact enforcement.