A practical, 90-day governance plan for banks and credit unions navigating the April 2026 OCC/Fed/FDIC model risk guidance and the fair-lending enforcement record building around AI underwriting.
Why Now
A July 2025 Massachusetts settlement established that an AI credit model can violate fair-lending law even without any intent to discriminate — and the April 2026 federal model risk guidance now puts new documentation obligations on every institution using AI in lending, regardless of size.
What's Inside
Everything translated from regulatory language into specific, assignable actions.
The Massachusetts precedent, the proxy-discrimination problem, and the current fair-lending enforcement climate.
A plain-language breakdown of the April 2026 guidance and what it changes.
ECOA, Reg B, disparate impact, and the adverse-action-notice "black box" problem.
Model inventory, bias testing, monitoring, explainability, and vendor governance.
Specific priorities for large banks, regional banks, community banks, and credit unions.
A sequenced, assignable path from "we think we're fine" to "we can prove it."
Who This Is For
No technical background assumed — it's built for the people accountable for the answer, not the model itself.
Translate the April 2026 guidance into a defensible, documented program.
Know exactly what documentation examiners and vendors will be asked for.
Get the specific questions to ask management before an examiner asks you first.
Sample Questions from the Playbook
"Do we know what AI is embedded in our core provider's credit-scoring tools, and can we get the documentation needed to satisfy our own model risk obligations?"
"Have we conducted pre-deployment bias testing on every AI credit model in use, documented thoroughly enough to survive examination?"
"Can our AI credit models produce adverse action notices specific enough to satisfy ECOA and Regulation B — tested against real denial scenarios?"
"Are we relying on a vendor's fair-lending representations, or have we independently validated equitable performance across protected classes?"
What You Receive
Editable Word file plus a polished PDF — ready to circulate to your board or compliance team as-is.
A sequenced, assignable checklist across inventory, testing, and governance phases.
Ready to drop directly into your next board deck or audit committee agenda.
Every regulatory citation and enforcement action documented and attributed.
Pricing
One-time purchase. No subscription.
Secure checkout · Delivered to your email immediately
Frequently Asked Questions
This is a focused, standalone briefing on AI credit decisioning and fair-lending compliance, including a new 90-day action plan not found in the flagship report. The full report covers five pillars across the entire AI-in-banking landscape.
No. This is independent research meant to inform your conversation with counsel and examiners, not replace it. Every regulatory citation is sourced so your team can go directly to the primary document.
It reflects the April 2026 OCC/Fed/FDIC model risk guidance and enforcement activity through mid-2026, including the Massachusetts AI underwriting settlement and current state enforcement posture.
Immediately by email upon purchase — both a PDF and an editable Word file, so your team can adapt the 90-day plan directly.