Public methodology
Measurements are evidence, not verdicts.
Avarent’s outputs are intended to support investigation and qualified review. A metric crossing a threshold is a prompt to examine context, not a standalone legal conclusion.
Methodology overview · version 1.0 · August 12, 2026
Adverse impact ratio
The adverse impact ratio compares a selected group’s favorable-outcome rate with a reference group’s rate.
A four-fifths or 0.80 threshold can be used as a screening convention. It does not, by itself, establish unlawful discrimination. Population definition, sample size, selection of reference group, policy context, and statistical uncertainty matter.
Statistical parity difference
Statistical parity difference expresses the absolute gap between favorable-outcome rates. Its direction, magnitude, sampling variability, and business context should be reviewed together.
Adverse-action reason review
Avarent can organize candidate explanations and supporting decision fields for human review. The creditor remains responsible for ensuring disclosed reasons are accurate, specific, and tied to factors actually considered or scored.
CFPB Circulars 2022-03 and 2023-03 were withdrawn on May 12, 2025. Avarent does not present withdrawn circulars as current supervisory guidance. The underlying ECOA and Regulation B obligations, including § 1002.9, should be evaluated with qualified counsel.
Known interpretation limits
- Observed disparity does not identify cause by itself.
- Small samples can produce unstable estimates.
- Missing, inferred, or misclassified demographic attributes can change results.
- Post-hoc explanations can approximate rather than reproduce a model’s internal reasoning.
- Thresholds should reflect institutional policy and qualified review, not software defaults alone.
- Results depend on the completeness and correctness of supplied data.
Primary references
Primary regulation, including notification requirements under § 1002.9.
↗Supervisory Guidance on Model Risk Management (SR 11-7)Federal Reserve and OCCModel development, validation, governance, policies, and controls.
↗Interagency Guidance on Third-Party RelationshipsFederal Reserve, FDIC, and OCCPlanning, due diligence, contracting, monitoring, and termination considerations.
↗AI Risk Management Framework 1.0NISTVoluntary framework organized around govern, map, measure, and manage.
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