01
ECOA / Reg B
12 CFR 1002.9 · credit
Adverse action reasons. A dropped reason is a reason legally owed and withheld — the sharpest test of certificate value.
reasonsmith audit engine · research preview
Prove which legally‑owed reasons a system deleted. And from whom.
Abstract
reasonsmith runs conformance checks against formal regulation packs and issues reason-deletion certificates: audit-grade evidence that an explanation engine dropped reasons the law says a person is owed. Every claim carries a strength on an explicit lattice — observed → probed → proved — and nothing claims a strength it did not earn.
§1 — The case
One credit decision.
Five reasons on file.
Application APP-1042, adverse action. Under ECOA / Reg B (12 CFR 1002.9)
the applicant is owed the specific principal reasons. The scoring system computed five:
income, credit history length, delinquent obligations, recent inquiries, references.
The graph behind you is the proof structure of that decision.
§2 — The deletion
The engine kept one.
It deleted four.
The explanation engine answers adverse_action(APP-1042) with a top‑1 proof.
The applicant sees one reason. The certificate shows what the full proof contained —
and what was dropped on the way out.
- used C01 — Income insufficient for amount of credit requested 0.7656
- deleted C02 — Length of time credit has been established is too short 0.6972
- deleted C03 — Delinquent past or present credit obligations 0.6320
- deleted C04 — Too many recent inquiries on credit bureau report 0.6004
- deleted C05 — Insufficient number of credit references provided 0.5112
§3 — The duties
Six regulations, one engine.
02
GDPR Art. 22
automated decisions · clinical
Meaningful information about the logic involved, owed to the data subject, in a triage setting.
03
EU AI Act Art. 13
transparency · deployers
Deployer information duties for high-risk systems: instructions, capabilities, limitations.
04
EU AI Act Art. 12
record-keeping · logs
Automatic event logs over the system's lifetime, retained for the regulatory lookback window.
05
FDA GMLP
SaMD · good machine learning practice
Design history, verification logs and change control for software as a medical device.
06
NIST AI RMF 1.0
continuous monitoring
Monitoring logs, thresholds, reviews and incident tickets as ongoing evidence, not one-off attestations.
§4 — The evidence
Nothing claims a strength
it did not earn.
Every requirement verdict carries its position on the evidence lattice. unattainable means the system as built cannot emit the signals at all; observed means the trace carries them; probed and proved mean the engines went further. Zero verdicts combine to inconclusive, never to satisfied.
unattainable→
observed→
probed→
proved