financial · FTC Act §5 · EEOC Title VII · NAIC Model Bulletin
Payday Lending / EWA Credit
Refused to fund — adverse action receipt for deployer file
—Predatory lending AI underwriting scrutiny
Regulatory exposure — commonly overlooked:
Lender uses AI score — lender owns usury finding, vendor owns model card theater. · Federal agencies disagree on AI approach — but examiners agree internal logs are insufficient.
TAM / Exposure
Grey-adjacent consumer finance · impulse borrow
Insurance lines
E&O · Consumer finance
Exhibit authority
US Federal Exhibit — Predatory Lending Refusal Pack