When a model denies a loan, someone has to explain why. AVAAS certifies that it can.
Credit is decided by models. Underwriting, approval, pricing, and limit decisions increasingly run through machine-learning systems that even their owners struggle to explain. Federal law does not accept the algorithm decided as an answer. AVAAS certifies the model at the point it acts on an applicant.
The decision point in lending
In lending, the AI acts when it approves or denies an application, sets a rate, assigns a limit, or flags an account. Each of those is an adverse action the moment it goes against the consumer.
Every adverse action carries a legal duty to give specific, accurate reasons, and an opaque model that cannot produce them is a compliance failure waiting to be found.
What keeps lenders exposed
Your model denies a loan and cannot say why
ECOA requires the principal reasons for any adverse action. A complex model that cannot produce them does not meet the standard.
Disparate impact you never intended
A model can price or deny along protected lines through proxies. If you are not testing for it, an examiner will.
Supervisors expect independent validation
SR 11-7 sets an expectation for model-risk management. Self-validation rarely satisfies a skeptical examiner.
Evidence the model does what ECOA requires
Can the model give specific, accurate reasons for every adverse action?
AVAAS evaluates the system with causal attribution, so a denial traces to the features that drove it rather than a post-hoc approximation.
Does it produce disparate impact across protected classes?
Five structurally independent validators test for demographic disparity in approvals and pricing.
Does independent validation exceed the SR 11-7 bar?
AVAAS is operated separately from the standard it certifies, so the validation is genuinely independent of the model owner.
You get documented, third-party evidence that the credit model does what the law requires, with sealed deployment verification confirming the certified model is the one in production.
Related AVAAS coverage: SR 11-7 · California ADMT · GDPR Article 22. Or run the free Regulation Checker to see what applies to you.
See where your lending AI creates liability.
Tell us where AI touches your underwriting, pricing, or account decisions, and we will scope an AVAAS certification to the exposure.
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