The ECOA Compliance Checklist for AI Lending Agents

What's Inside

• Adverse Action Notice Requirements — Verify your AI agent generates compliant notices with specific reason codes for every denial, counteroffer, or unfavorable term change
• Prohibited Basis Checks — Ensure your model does not use race, color, religion, national origin, sex, marital status, age, or public assistance status as decision factors
• Proxy Discrimination Testing — Identify features that correlate with protected classes (zip code, institution type, employment patterns) and test for disparate impact
• Spousal Signature Rules — Confirm your agent does not require a spouse's signature, co-signature, or guarantee in violation of Regulation B
• Record Retention Requirements — Validate that all applications, adverse action notices, and decision logs are retained for the required 25-month period
• Notification Timing — Ensure adverse action notices are delivered within 30 days of the credit decision or 90 days of an incomplete application
• Explainability Documentation — Confirm every AI-driven denial includes a human-readable explanation of the principal reasons for the adverse action
• Monitoring & Audit Trail — Establish ongoing monitoring for ECOA compliance with immutable audit logs for regulatory examinations

Related Reading

• ECOA Adverse Action Notices for AI Lending Decisions
• Fair Lending Risk in AI Underwriting
• SR 11-7 AI Model Governance Guide