Colorado ADMT rules: hearing and last day for written comments · Oct 26, 2026 · See what changes
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In 2022 the CFPB issued Circular 2022-03, saying lenders must give specific, accurate reasons for adverse action even when a complex algorithm made the decision. The CFPB withdrew that circular on May 12, 2025, along with many other guidance documents. The underlying rule still applies: ECOA and Regulation B require specific reasons in an adverse action notice, so 'the model said no' is not enough. Separately, a final rule published April 22, 2026 and effective July 21, 2026 amended Regulation B to provide that ECOA does not authorize disparate-impact liability.
If your product uses AI to make or assist in credit decisions, such as loan underwriting or credit line setting, you must still be able to explain specifically and accurately the factors behind each adverse decision. The withdrawal does not remove that duty, because it comes from the regulation and not the circular. Disparate-impact theories are narrower under ECOA after the 2026 rule, so check state law and other federal laws that may still apply. Models that cannot produce interpretable reasons for their outputs are a compliance risk.