Replay of a real run — captured 2 Jul 2026
Equipoise
Fair-Lending Reviewer
Every step below is a real trace event from the signed run ledger.
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Transcript
I'll kick off the review by pulling everything I need in parallel — the application file, credit policy, and monitoring attributes all at once.
Good — I have the application, policy, monitoring data, and one comparator. Now I need to pull the credit reports for both L11 and comparator L12 before I can assess credit-profile parity.
I now have a complete picture. Let me compile my analysis before recording.
Pre-Record Analysis
Step 1 — Is the decision supported by policy?
| Criterion | Policy Limit | L11 Actual | Pass/Fail |
|---|---|---|---|
| Min. credit score (auto) | ≥ 600 | 666 | PASS |
| Max. DTI | ≤ 45% | 13% | PASS |
| Max. LTV | ≤ 125% | 102% | PASS |
| Derogatories / public records | None hard-stop | 0 / 0 | PASS |
| Thin file | Refer trigger | False | PASS |
Critical finding: The policy's near-prime band (660–719) maps to a 9.49% rate — it is an approved tier, not a decline category. The minimum score for decline on auto is below 600. A score of 666 clears every hard threshold. The stated policy basis ("score 666 in the near-prime band") does not constitute a valid decline trigger. The decision is unsupported.
Step 2 — Outcome Testing: L11 vs. L12 (Gregory Hale)
| Attribute | L11 (André Mensah) | L12 (Gregory Hale) |
|---|---|---|
| Score | 666 | 669 (+3 pts) |
| Utilization | 33% | 31% (-2 pts) |
| DTI | 13% | ~12% |
| LTV | 102% | ~102% |
| Derogatories | 0 | 0 |
| Public records | 0 | 0 |
| Inquiries (6 mo) | 2 | 2 |
| Oldest account | 78 mo | 80 mo |
| Employment tenure | 48 mo | 45 mo |
| Tradelines (all current) | 2 | 2 |
| Product / purpose / channel | Auto / purchase / direct | Auto / purchase / direct |
| Decision | DECLINE | APPROVE |
| Race/ethnicity | Black | White |
The profiles are materially equivalent. L11 actually has greater employment tenure. The 3-point score gap and 2-point utilization gap are de minimis and lie nowhere near any policy threshold. There is no legitimate, policy-grounded explanation for the divergent outcomes. The sole meaningful axis of difference is race/ethnicity.
Step 3 — Proxy check: The stated factors ("credit score in the near-prime range," "moderate revolving utilization") contain no facially race/ethnicity-proxying language. However, these same factors were present in L12's file, which was approved — the factors were applied selectively, which is itself a form of disparate treatment.
Verdict: VIOLATION — A similarly-situated White applicant (L12) received a materially more favorable outcome than a Black applicant (L11) whose file fully satisfies policy, with no policy-grounded explanation for the difference.
The decision brief
Fair-Lending Review — Final Report: VIOLATION
Application: L11 — André Mensah | Auto Loan, $24,000 | Decline
Decision Supported by Policy? No.
Every hard policy threshold for an auto approval is cleared:
- Score 666 ≥ 600 minimum ✅
- DTI 13% ≤ 45% cap ✅
- LTV 102% ≤ 125% cap ✅
- No derogatories, no public records ✅
The near-prime score band (660–719) triggers a rate of 9.49%, not a decline. The stated policy basis is factually inapplicable.
Outcome Testing — Driving Comparator: L12 (Gregory Hale)
L12 is a near-identical applicant — same product, channel, purpose, employment category, loan structure, and vehicle — who was approved. The only credit differences are 3 score points and 2 utilization points; L11 actually has longer employment tenure. There is no legitimate, policy-grounded explanation for the divergent outcomes.
| L11 (André Mensah) | L12 (Gregory Hale) | |
|---|---|---|
| Race/ethnicity | Black | White |
| Score | 666 | 669 |
| Outcome | Decline fail | Approve pass |
Findings Summary
- Unsupported decline — no hard-stop criterion is triggered; near-prime is a rate tier, not a decline category.
- Disparate treatment — materially equivalent White applicant approved while Black applicant declined; no policy basis distinguishes the outcomes.
- Selective factor invocation — the cited factors ("near-prime score," "moderate utilization") appear in both files; only L11's application was denied.
- Anomalous confidence score (0.62) — suggests a non-policy factor may have influenced the decision.
- No proxy language detected in the stated factors.
Recommendation
🚨 Escalate immediately to Fair Lending Compliance and General Counsel. Rescind the decline and re-underwrite L11 (approve at the 9.49% near-prime rate). Audit all near-prime auto decisions over the past 12–24 months for systemic patterns. Identify involved underwriter(s). Assess regulatory self-reporting obligations if a pattern is confirmed. Strengthen second-line controls requiring documented policy-basis justification on any decline where all thresholds are met.