CFPB — Adverse-Action / ECOA Guidance on AI Credit Decisions
September 2023 CFPB circular confirming that ECOA / Regulation B require lenders to provide specific and accurate reasons for adverse actions even when the decision was made by a complex algorithm or 'black-box' ML model. The 'no black-box' rule survived CFPB's April 2026 narrowing of disparate-impact enforcement.
Not legal advice. This dataset is an aggregation of public regulatory text for informational purposes only. It is not legal advice and is not a substitute for counsel. Verify against the linked primary sources before relying on any row.
- Issuer
- Consumer Financial Protection Bureau
- Sector
- Lending / fintech
- Primary source
- Primary source ↗
- Row count
- 1 jurisdictions covered
Rows
| Jurisdiction | Status | Effective | Last verified | Summary | Source |
|---|---|---|---|---|---|
| Federal | Adopted | 2023-09-19 | 2026-07-08 | CFPB's September 2023 circular (and the underlying ECOA / Regulation B) requires lenders to provide specific and accurate reasons for adverse actions even when the decision was made by a complex algorithm or 'black-box' ML model. The 'no black-box' rule survived CFPB's April 2026 narrowing of disparate-impact enforcement. Lenders using AI/ML in credit decisions must be able to identify the principal reasons for denial to applicants. | Primary source ↗ |