Advisory mode
During the pilot, all compliance events require human validation. Legal approval is required to mark an event as resolved or risk accepted.
Silent Non-Compliance: Auto Lending Disclosure
Days Open
7d
Customers
14,200
Exposure
$4.2M
Business Unit
Auto Lending
SLA
Ack 60m · Resolve 4d
What Changed
Template AA-AUTO-001 modified: removed required AI-decision disclosure clause
Diff from Google Drive / Salesforce CMS
4/26/2026, 1:00:00 PM by John Smith
Before
Your application was evaluated using an automated model. Key factors considered include: [MODEL_FACTORS].
After
Your application was evaluated. You did not meet our underwriting criteria.
Affected Asset
Last changed 2026-04-25 by James Okafor
What Broke
Regulation
CFPB Circular 2026-04: AI Decision Transparency in Consumer Lending
Section
CFPB-2026-04 Section 4.2(b)
Obligations breached
Owner
Senior Compliance Officer / Auto Lending Compliance
1 SLA breach(es) active
Business Unit
Auto Lending
Risk score: 74
Remediation Actions (0/7)
System Actions
Compliance event created
6/1/2026, 9:44:59 PM
Draft resolution package generated
6/1/2026, 9:44:59 PM
SLA started
Ack 60m, resolve 4d
Owner notified (Slack and email)
6/1/2026, 9:44:59 PM
Task created in system of record
Simulated ServiceNow or OneTrust ticket
Post-resolution baseline updated
Not applicable
Acknowledgment status
Overdue
Draft Resolution Package
What broke and why
CFPB-2026-04 Section 4.2(b) obligation may no longer be satisfied.
This event was generated because a monitored enterprise asset changed after validation. The obligation-to-asset relationship must be revalidated and evidenced.
Draft compliant version
Draft language: "Your application was evaluated using an automated model. Key factors that contributed to this decision include: (1) payment history, (2) debt-to-income ratio, and (3) recent credit inquiries. You may request additional information about the factors used in this decision by contacting ..."
Draft only. Human review and legal sign-off required.
Evidence Checklist
Audit Trail
Compliance Event created: Drift detected
System · 6/1/2026, 9:44:59 PM
Draft resolution package generated
System · 6/1/2026, 9:44:59 PM
SLA countdown started
System · 6/1/2026, 9:44:59 PM
Notifications sent (Slack + email simulated)
System · 6/1/2026, 9:44:59 PM
Ticket created in system of record (simulated)
System · 6/1/2026, 9:44:59 PM
Enforcement Context