Regulation B requires the specific principal reasons the decision actually used. A fluent explanation of a decision the model did not make is the failure, and the CFPB circulars people cite were withdrawn in 2025.
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Obligations attach to role, risk class, and the act of placing on the market. Real-world testing is carved out of the pre-market exclusion, and the 2026 amendments moved the high-risk dates.
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SR 26-2 replaced SR 11-7 in April 2026 and its footnote 3 puts generative and agentic AI outside scope. Being out of scope routes the work elsewhere; it does not remove it.
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One is a voluntary risk framework applied to a system, the other a certifiable management system applied to an organisation. Cited as alternatives, they answer different questions and neither certifies an application.
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