ATLAS-7 consumer credit model
- To
- Model Risk Committee
- From
- Lead Validator
- Date
- 16 October 2026
- File
- VR-2026-114 · sample case
Opinion
Return to developer
Findings
High Target leakage from post-decision data
Evidence: Feature timing review, 3 post-decision features. SR 11-7 conceptual soundness · EU AI Act Art. 10.
High Unstable adverse action reasons
Evidence: Reason-code stability test, top-reason flip rate 31%. Reg B §1002.9 · EU AI Act Art. 86.
Medium Applicant population has shifted
Evidence: Population stability index 0.31. SR 11-7 outcomes analysis.
Scope limitations
Not performed within the review window: Calibration by risk decile; Documentation review.

