CFPB · Regulation B
Can an AI credit decision give “failed our score” as its adverse-action reason?
Content reviewed 2026-10-10 · How we check sources
Short answer
No. Where Regulation B requires a statement of reasons, a generic failure to meet a score is insufficient. The reasons must identify the principal factors actually considered or scored in the decision.
Applies to: Consumer-credit notice reasons · not a full AI or lending review
What this means
Section 1002.9(b)(2) rejects generic references to internal standards, policies or a qualifying credit score. The official interpretations require reasons that accurately describe the actual decision factors.
Section 1002.9(a)(2) permits either reasons in the written notice or the prescribed disclosure of the right to request them. Other notice content, timing, exceptions, FCRA and state requirements need a separate assessment.
Your next step
- Check whether your model can recover the actual principal reasons.
- Test a sample notice against those reasons.
- Record the notice control owner and assess the other applicable requirements.
Suggested workflow; confirm applicability for your institution.
Official sources
CFPB Regulation B — § 1002.9(a)(2), (b)(2) and official interpretations ↗Ask with your entity, activity and regulator.
Regulatory research, not legal advice. This answer has the scope and review date shown above; your institution decides applicability.