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> If the mortgage application evaluation system is deterministic so that the same input always produces the same output then it is easy to answer "Why was my ap
by xvokcarts 2y ago
> If the mortgage application evaluation system is deterministic so that the same input always produces the same output then it is easy to answer "Why was my application rejected?".
But banks, at least in my country (central EU), don't have to explain their reasons for rejecting a mortgage application. So why would their automated systems have to?
- tzs 2y agoIn the US they do have to explain. It's a requirement of the Equal Credit Opportunity Act of 1974 [1]. Here is an article with more detail on what is required in the explanation [2]. [1] https://en.wikipedia.org/wiki/Equal_Credit_Opportunity_Act#Requirements https://en.wikipedia.org/wiki/Equal_Credit_Opportunity_Act#R... [2] https://www.nolo.com/legal-encyclopedia/do-lenders-have-to-tell-you-why-you-are-denied-credit.html https://www.nolo.com/legal-encyclopedia/do-lenders-have-to-t...
- Muromec 2y agoThey don't have to explain to the applicant. They do have to explain to the regulator how exactly they stay compliant with the law. There is so called three line system -- operational line does the actual thing (approves or rejects the mortgage), the second line gives the operational line the manual to do so the right way, the internal audit should keep an eye that whatever the first line is doing is actually what the policy says they should be doing. It's entirely plausable that operational line is an actual LLM which is trained on a policy that the compliance department drafted and the audit department occasionally checks the outputs of the modal against the policy. But at this point it's much easier to use LLM to write deterministic function in your favorite lisp based on the policy and run that to make decisions.