BB-UW-0098 FLAG
On 2026-10-15, uw-triage v2.4 (an internally developed system) produced 'approve' in a TX auto underwriting transaction. Inputs included application data, claims history, consumer report, credit, geography. A consumer report was used. No human reviewed the output before it took effect. The outcome was not adverse to the consumer. RegBench applied 11 rule(s) in force on 2026-10-15 and recorded 2 finding(s); the most serious is 'Consumer report used with no data source reference recorded' (low, L0).
FLAG: 2 finding(s) under rules 2026.10+dbe5ddf6, corpus 2026-10-30-5f07c521. Routed to the carrier's compliance reviewer with cited findings.
Findings (2)
Consumer report used with no data source reference recorded
Finding. A consumer report was used but the transaction records no data source reference, so the permissible purpose and the furnishing agency cannot be evidenced from the case file.
Basis. FCRA § 604(a)(3)(C) permits use of a consumer report in connection with the underwriting of insurance; the case file should identify the report and the agency so the permissible purpose and any later § 615 notice can be evidenced.
Required action. Record the consumer reporting agency and report reference on the transaction.
Excerpt: us-fcra-1681b-a-3-c · federal statute (public domain) · in force from 1971-04-25
"[A]ny consumer reporting agency may furnish a consumer report under the following circumstances and no other: ... (3) To a person which it has reason to believe ... (C) intends to use the information in connection with the underwriting of insurance involving the consumer".
Third-party data used with no source recorded
Finding. The decision used data from a third party, and the transaction records no data source, so the accuracy of the data cannot be traced or corrected.
Basis. Bulletin B-0036-20 reminds regulated entities that they "are responsible for the accuracy of the data used in rating, underwriting, and claims handling" even when "the data is provided by a third party", and encourages a way for policyholders to review and correct it.
Required action. Record the data source reference so the data can be traced and corrected.
Excerpt: tx-tdi-b-0036-20 · regulatory bulletin addressed to all regulated entities and their agents (government edict) · in force from 2020-09-30
Regulated entities "are responsible for the accuracy of the data used in rating, underwriting, and claims handling", "even if the data is provided by a third party"; "TDI may pursue enforcement action against an insurer if its use of inaccurate data harms policyholders"; "Insurers are encouraged to provide policyholders with a way to review and correct data being used by the insurer." The bulletin states it does not create a new legal duty.
Point in time
- Law as of
- 2026-10-15
- Rules version
- 2026.10+dbe5ddf6
- Corpus snapshot
- 2026-10-30-5f07c521
- Engine
- regbench-engine/0.4.0 · deterministic-1
- Fingerprint
- 6ab443c05c6fe5bd4895828f
- Evaluated
- 2026-10-30 11:23:22 UTC
- Exhibit C case file
- yes
Ledger
- Entry
- #98 · assessment · recorded 2026-10-15T14:56:21+00:00
- Hash
- bf3ac86a5a03e810e044519e0b49dbbf2d921c951a43e43bb41f6cd778709547
- Previous
- 7ef37006fe2e18bb3d431351d05f7675ae29bc9ea9adf62201fb618b8d4772c4
- Stored copy intact
- yes, hashes match
Carrier review
Resolved by underwriter · outcome remediated · 71.3 hours after it opened · Resolved in the carrier's review queue (synthetic).
Recorded facts
- AI system
- uw-triage v2.4 · internal · high-risk class: underwriting
- Governance attested
- True
- Testing report
- test://bluebonnet/uw-triage/2026Q3
- Model documentation
- doc://bluebonnet/uw-triage/2.4
- Feature classes
- application_data, claims_history, consumer_report, credit, geography
- Protected factors used
- none
- External data (ECDIS)
- False
- Consumer report / credit
- True / True
- Data sources
- none recorded
- Decision
- approve · score 0.189
- Human review
- none
- Adverse to consumer
- False
- Notice
- not recorded · reasons: False · specific: False · external data disclosed: False
- Appeal channel
- –
- Consumer token
- tok_e94d8984a3