Industries · Credit Unions

Prove every member decision was fair — before NCUA asks.

EVE CoreGuard enforces your fair-lending policy — ECOA, Reg B, FCRA, Fair Housing — on each AI-assisted member-loan decision before the model’s output reaches a member, and signs a replayable evidence record an NCUA examiner can verify offline. Protect the member relationship by proving the decision was right.

Policy decision in <1ms  ·  Signed, hash-chained record  ·  Offline-replayable for NCUA examiners
Enforces against ECOA / Reg B FCRA Fair Housing Act Military Lending Act UDAAP
The exam question

A model card won’t answer “prove this AI decision was fair to the member.”

Automated and AI-assisted underwriting is moving into member-loan and credit decisioning, account opening, fraud, and collections. The problem isn’t whether the model is accurate — it’s whether you can prove, decision by decision, that it stayed inside fair-lending law and treated members consistently. A probabilistic model plus application logs cannot show an NCUA examiner why a specific member was denied, that the adverse-action reasons were present, or that the same member profile gets the same answer every time.

ECOA · Reg B · FCRA

Adverse-action exposure to members

A denial that lacks the specific principal reasons required by Reg B (12 CFR 1002.9) and FCRA is a violation per notice — and these scale across every member loan you decline.

ECOA · Fair Housing Act

Fair-lending exposure on member loans

Fair-lending obligations apply to member-loan decisioning just as they do at banks. An automated decision that disadvantages a protected class is a finding waiting for an NCUA exam — and a hit to member trust.

NCUA supervision

Smaller compliance teams, same exam

NCUA — not OCC or FDIC — supervises your fair-lending program. A credit union faces the same exam expectations as a bank, often with a fraction of the compliance headcount to document each decision.

UDAAP

Inconsistent member decisions

If the same member profile can get different outcomes across model versions, you can’t explain — or defend to the member or the examiner — why a given decision happened.

What EVE CoreGuard does

Deterministic enforcement, then signed evidence — on every member decision.

CoreGuard sits in front of your member-loan model as a governance layer. It evaluates each proposed decision against your lending_v1 policy pack — the same fair-lending pack (ECOA / Reg B) banks use — and returns ALLOW, BLOCK, or MODIFY before the output is finalized, then writes a cryptographically signed record of exactly which rule fired and why.

1

Enforce policy before the member decision is final

The lending_v1 pack encodes ECOA / Reg B / FCRA / Fair Housing rules. The same input always produces the same governance decision — deterministic, not probabilistic.

2

Block adverse actions that lack required reasons

If a member denial is missing the principal reason codes Reg B and FCRA require, CoreGuard blocks it and records the gap — so the notice the member receives matches the record you keep.

3

Gate every model update through the Model Update Firewall

Each model change is simulated against your fair-lending rules and blocked before promotion if it introduces disparate impact on members. See the EVE Model Update Firewall →

4

Hand the NCUA examiner a record they can verify themselves

Every decision becomes a signed, hash-chained evidence record (Ed25519 in production). Re-hash and re-verify it offline with the public key — no EVE service required. Verify a record →

governed decision · signed evidence record ✓ VERIFIED
decision_idDEC-00042
policylending_v1 · ECOA / Reg B
verdictBLOCK — adverse-action evidence required
content_hashsha256:3204f3d6…1ef0f3130
signatureed25519:4e542efc…a10250b02
Sample record · re-hash + Ed25519 re-verify, no EVE service required Verify a record offline →
The economics

One prevented fair-lending event pays for years of governance.

The price tag on a single member-lending governance failure — and the member trust it costs — dwarfs the cost of the control that prevents it.

Governance failureIllustrative costWhat drives the number
Fair-lending investigation or settlementECOA / FHA · disparate impact on members
$2M–$30M+
Public DOJ / CFPB consent orders pair a civil penalty with a consumer remediation fund.
Adverse-action notice failuresECOA / Reg B · FCRA
$100K–$1M+
FCRA statutory damages run $100–$1,000 per affected consumer (15 U.S.C. §1681n) and scale with the number of members affected.
Adverse NCUA fair-lending findingDocument of Resolution / remediation
$500K–$2M+
Lookback review, outside consultants, and added compliance staffing to clear a documented examination finding.

Illustrative ranges drawn from public regulatory penalty caps, published enforcement actions, and statutory damages — not EVE customer results. Model your own exposure with the ROI calculator. EVE CoreGuard’s Enforcement license is $150,000/year.

Deployment

Member data never leaves your tenant.

CoreGuard runs as SaaS, in your VPC, or fully on-prem. The governance decision and the signed record are produced inside your boundary — nothing about a member is sent to EVE to make a decision. See deployment models →

SaaS

Fastest start. Decisions and signed records produced in an isolated tenant.

VPC / Private

Runs inside your cloud account, under your network and key controls.

On-prem

Air-gap-friendly for credit unions that keep member decisioning fully in-house.

Examiner access

Issue scoped, time-boxed evidence links so an NCUA examiner can verify records directly.

Questions buyers ask

Member fair-lending governance, answered plainly.

No. Your model and your loan officers make the decision. CoreGuard governs it: it evaluates the proposed action against your fair-lending policy pack before the output is finalized, returns ALLOW / BLOCK / MODIFY, and produces a signed evidence record. It is a governance and evidence layer, not a credit model — and it never touches the member relationship beyond enforcing the policy you already owe your members.
When an AI-assisted decision results in a member denial, Reg B (12 CFR 1002.9) and FCRA require specific principal reasons. CoreGuard can block a denial that lacks the required reason codes and record the reasons that were present — so the notice the member receives and the record you keep are consistent and traceable to the rule that fired.
NCUA supervises your credit union and conducts fair-lending examinations under ECOA and the Fair Housing Act. CoreGuard applies deterministic, versioned policy — the same input always produces the same governance decision — and writes a signed, hash-chained audit trail. When an examiner asks you to prove a specific member decision was compliant, you hand over a decision-level record instead of a model card and a stack of logs.
Yes. Each record carries a content hash and a cryptographic signature (Ed25519 in production). An examiner can re-hash the record and re-verify the signature offline with the public key, no access to EVE’s service required. Verification proves the record was not altered after the decision was made.
Engagements start with a $37,500 design-partner pilot, scoped to a single member-loan workflow — a right-sized starting point for a credit union’s compliance team — with the pilot fee credited toward an annual license. The Enforcement license is $150,000/year. See the pricing page for current tiers.

Bring one member-loan workflow under deterministic governance.

A 60-day design-partner pilot puts CoreGuard in front of a single member-decision flow, produces signed evidence on real decisions, and credits the pilot fee toward your license.

Built by a lending-technology founder. 90 U.S. patent applications filed.