Appendix A: Externally Verifiable Decision Records
Under rules already in force, a creditor must give specific and accurate reasons for an adverse action even when a complex model produced the outcome, and lack of model understanding is not a defense (CFPB Circular 2022-03). The sample records below were captured outside the deciding system and signed with an independent key. Any reviewer can verify them without trusting the deciding system or the auditor.
| applicant_ref | decision | principal_reasons | model_version | recorded_at | verify |
|---|
Method: ECDSA P-256, signature verified here against the embedded demo public key. Production verifiers use a public key served separately from the record. Append-only storage, optional RFC 3161 timestamp. The record is tamper-evident and does not assert absolute immutability.