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CFPB says lenders using AI models must give specific reasons when they deny credit

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CFPB Circular 2023-03, issued on 19 September 2023, says creditors using AI or complex credit models cannot rely on the checklist of reasons in Regulation B’s sample forms if those reasons do not accurately and specifically state why credit was denied or cut. The circular gives examples: a model that reduces a credit line because of where a customer shops must say more than “purchasing history”. It applies to new applications and existing accounts under the Equal Credit Opportunity Act.

Why it matters

US lenders using black-box credit models were told that the model’s complexity does not excuse vague denial notices, so they need models that can explain each decision.

When
19 Sep 2023
ID
WTA-N-2023-0094
Who
Consumer Financial Protection Bureau

Summary by wheresthe.ai, from Consumer Financial Protection Bureau. Checked against the source on 9 Oct 2026.

Source copy: download the source PDF as saved on 18 Oct 2026 (PDF). Document the source offers: the source PDF. Also held by the Internet Archive.

Next stop on this Storyline: What happened nextEU consumer credit law gives borrowers human review of automated credit checks

Cite this story

WTA-N-2023-0094: “CFPB says lenders using AI models must give specific reasons when they deny credit.” wheresthe.ai, 19 Sep 2023. https://wheresthe.ai/d/us-cfpb-circular-adverse-action-ai-credit-2023-09/ (source: Consumer Financial Protection Bureau).

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