AI Decision Evidence · Lending & Banking

AI Audit Trails for Lending
backed by proof

Regulatory note: the Federal Reserve issued SR 26-2, superseding SR 11-7 and SR 21-8 as interagency model risk management guidance. The OCC has stated that generative and agentic AI are novel technologies not themselves within the revised guidance’s scope. EVE supports evidence, validation, governance, and control practices that may help institutions operationalize portions of the 2026 guidance; applicability depends on the system, institution, and use case.

Every automated credit decision becomes a signed, reason-coded certificate an examiner can verify independently — and reproduce. Fair-lending review stops being a reconstruction and becomes a lookup.

The Obligation

What examiners require

These map to concrete EVE Proof capabilities — enforcement, reproducibility, and signed evidence — not a policy PDF.

ECOA / Reg B

Adverse-action reasons captured as structured reason codes, decided before the action — not reconstructed for the examiner.

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SR 26-2

Model-risk review independently reproduces each decision under its policy version, without relying on the first line.

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Evidence on demand

Per-applicant evidence packs prove how each applicant was treated, with signed inclusion proofs.

In Practice

Where evidence changes the conversation

1

Adverse action, explained

When a loan is declined, the certificate already carries the reason code and policy version — the adverse-action notice is backed by a verifiable record, not a screenshot.

2

An examiner asks 'prove it'

Hand over a date-ranged evidence pack and a public key. The examiner verifies every decision on their own machines, on their own timeline.

3

A model updates

Because policy is decoupled from the model and versioned, you can show exactly what changed and when — and replay any prior decision under the policy that produced it.

Frameworks

Mapped, not marketed

Informational mapping, not legal advice — EVE Proof supports your compliance program; it does not replace counsel.

FrameworkObligationEVE Proof capability
ECOA / Reg BAdverse action reasons; non-discriminationReason-coded, signed decisions + per-applicant evidence packs.
SR 26-2Model risk; effective challengePolicy decoupled from the model; independent, reproducible verification.
EU AI ActArt. 12 record-keeping (high-risk credit)Automatic, tamper-evident decision records.
Keep Reading

Related

See a real certificate verify

Verify a live decision certificate in your browser — then hand the evidence to your own auditor and watch them verify it without us.

FAQ

Common questions

Is this fair-lending compliant out of the box?
EVE Proof provides verifiable evidence and reason-coded decisions that support ECOA/Reg B and SR 26-2 programs. It is infrastructure for your compliance program, not legal advice.
Can we prove how a specific applicant was treated?
Yes — a per-applicant evidence pack carries the signed certificate and a Merkle inclusion proof for that decision, verifiable independently.
Does the certificate expose applicant PII?
No. It stores a SHA-256 digest of the request, not the raw application data, plus the verdict, reason code, and policy version.
One Control-Plane Stack

Governance decides. Enforcement acts. Proof attests.

The EVE Control-Plane Stack

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