[{"data":1,"prerenderedAt":192},["ShallowReactive",2],{"uc-reg-eba-loan-origination":3},{"regulation":4,"includeUnpublished":11,"indexable":12,"useCases":13},{"id":5,"label":6,"issuer":7,"region":8,"url":9,"description":10},"eba-loan-origination","EBA Guidelines on loan origination and monitoring","European Banking Authority","europe","https://www.eba.europa.eu/regulation-and-policy/credit-risk/guidelines-on-loan-origination-and-monitoring","Expectations for credit decisioning, including the use of automated models.",false,true,[14,44,65,83,98,114,148,165,178],{"slug":15,"title":16,"shortTitle":17,"definition":18,"status":19,"industries":20,"functions":22,"patterns":26,"audience":31,"autonomy":32,"adoptionStage":33,"segment":34,"evidenceCount":35,"publicEvidenceCount":35,"organizations":36,"bestGrade":39,"headline":40,"lastVerified":41,"indexable":12,"euAiActTier":42,"euAiActBasis":43},"credit-memo-drafting-agent","AI agent for corporate credit analysis and credit memo drafting","Credit underwriting and memos","An AI agent that gathers a corporate borrower's documents and data, spreads the financials into the bank's template, calculates ratios and covenant headroom, pulls bureau and news information, and drafts a committee ready credit memo in which every figure links to its source, for the relationship and credit teams to challenge, complete and sign.","published",[21],"banking",[23,24,25],"lending-and-credit","underwriting","risk-management",[27,28,29,30],"document-processing","agentic-workflow","rag-knowledge-assistant","content-generation","employee-facing","copilot","early-adopters","specialized-businesses",2,[37,38],"Banestes","DBS Bank","B",null,"2026-09-27","context-dependent","Annex III point 5(b) makes AI used to evaluate the creditworthiness of natural persons high risk. Credit analysis of companies is outside that point, but the tier can change when the same system evaluates the creditworthiness of natural persons, such as sole traders, partners who are personally liable or personal guarantors. Design the scope explicitly and document it.",{"slug":45,"title":46,"shortTitle":47,"definition":48,"status":19,"industries":49,"functions":50,"patterns":51,"audience":54,"autonomy":55,"adoptionStage":33,"segment":56,"evidenceCount":57,"publicEvidenceCount":57,"organizations":58,"bestGrade":39,"headline":40,"lastVerified":63,"indexable":12,"euAiActTier":42,"euAiActBasis":64},"sme-cash-flow-underwriting","AI cash flow underwriting for small business loans","SME cash flow underwriting","An underwriting engine that assesses a small business's repayment capacity from live bank transactions, point of sale and payment flows, receivables and accounting data instead of audited accounts, and returns a decision recommendation with the evidence and reasons behind it.",[21],[23,24,25],[52,27,28,53],"prediction-and-scoring","conversational-agent","back-office","supervised-agent","lending",4,[59,60,61,62],"MYbank","National Australia Bank","OakNorth Bank","Sumitomo Mitsui Banking Corporation","2026-09-26","Annex III point 5(b) makes AI systems that evaluate the creditworthiness of natural persons or establish their credit score high risk. Scoring a company is outside that point, but a sole trader is a natural person, and a model that also assesses the personal credit of owners, partners or guarantors evaluates natural persons. The tier therefore depends on who the borrower is and whose creditworthiness the model assesses.",{"slug":66,"title":67,"shortTitle":68,"definition":69,"status":19,"industries":70,"functions":72,"patterns":73,"audience":54,"autonomy":55,"adoptionStage":33,"segment":56,"evidenceCount":74,"publicEvidenceCount":74,"organizations":75,"bestGrade":39,"headline":40,"lastVerified":63,"indexable":12,"euAiActTier":81,"euAiActBasis":82},"alternative-data-credit-scoring","AI credit scoring with alternative data for thin file applicants","Alternative data credit scoring","A machine learning credit model that adds consumer permissioned alternative data, such as bank account cash flow, rent, utility and telco payments or ecosystem data, to credit bureau data, so a lender can assess applicants with thin or no credit files and return a decision with specific reasons.",[21,71],"payments",[23,24,25],[52,27,53],5,[76,77,78,79,80],"Atlanticus","Golden 1 Credit Union","GXS Bank","Patelco Credit Union","Upstart Network","high","Annex III point 5(b): AI systems intended to evaluate the creditworthiness of natural persons or establish their credit score are high risk, except systems used to detect financial fraud. Providers need risk management, data governance, logging and human oversight. Deployers must carry out a fundamental rights impact assessment before use (Article 27), and affected persons have a right to an explanation of individual decisions from the deployer (Article 86).",{"slug":84,"title":85,"shortTitle":86,"definition":87,"status":19,"industries":88,"functions":89,"patterns":92,"audience":31,"autonomy":32,"adoptionStage":93,"segment":56,"evidenceCount":35,"publicEvidenceCount":35,"organizations":94,"bestGrade":39,"headline":40,"lastVerified":41,"indexable":12,"euAiActTier":42,"euAiActBasis":97},"adverse-action-explanations","AI drafted explanations for credit declines and adverse actions","Adverse action explanations","An assistant that turns the reason codes of a credit model into an accurate, specific and readable explanation of a decline, reduced limit or repricing for the customer, and a matching internal rationale for the file, without adding any reason the model did not produce.",[21,71],[23,90,91],"regulatory-compliance","customer-service",[30,29,53],"emerging",[95,96],"Discover Financial Services","Wells Fargo","The drafting assistant does not assess creditworthiness, so on its own it is not the Annex III point 5(b) credit scoring system. It helps the lender meet the Article 86 right of affected people to a clear and meaningful explanation of decisions based on such a high risk system. If it is built into the scoring system it shares that system's high risk obligations; as a separate drafting tool its tier depends on its design and on how its output is reviewed. The follow up chat assistant must tell customers they are dealing with an AI system (Article 50).",{"slug":99,"title":100,"shortTitle":101,"definition":102,"status":19,"industries":103,"functions":104,"patterns":105,"audience":31,"autonomy":108,"adoptionStage":33,"segment":56,"evidenceCount":109,"publicEvidenceCount":109,"organizations":110,"bestGrade":112,"headline":40,"lastVerified":41,"indexable":12,"euAiActTier":42,"euAiActBasis":113},"credit-early-warning-monitoring","AI early warning and covenant monitoring for loan portfolios","Credit early warning and covenants","A monitoring system that tracks covenant tests and borrower reporting across a loan book, reads financials, filings and news, and combines them with payment and sector signals to flag borrowers whose credit is deteriorating, with the evidence and a suggested next step for the relationship manager.",[21],[25,23],[106,27,28,107],"anomaly-detection","summarization","assist",3,[61,111,62],"PNC Financial Services","C","Monitoring the credit of companies is not listed in Annex III. Where the same system evaluates the creditworthiness of natural persons, such as sole traders or personal guarantors, it falls under Annex III point 5(b) and is high risk; because that evaluation profiles natural persons, the Article 6(3) exemption does not apply.",{"slug":115,"title":116,"shortTitle":117,"definition":118,"status":19,"industries":119,"functions":123,"patterns":126,"audience":54,"autonomy":55,"adoptionStage":33,"segment":128,"evidenceCount":129,"publicEvidenceCount":129,"organizations":130,"bestGrade":39,"headline":137,"lastVerified":63,"indexable":12,"euAiActTier":42,"euAiActBasis":147},"application-and-identity-fraud-detection","AI for application and identity fraud detection","Application and identity fraud","AI that checks incoming account and loan applications for forged or AI generated documents, synthetic and stolen identities, and coordinated application rings, by analysing documents, device and application data across the whole queue and cross checking against bureau and official sources.",[21,71,120,121,122],"cross-industry","government","telecommunications",[124,125,23],"fraud-prevention","onboarding-and-kyc",[27,106,127,52],"computer-vision","front-office",6,[131,132,133,134,135,136],"BCU","Close Brothers Motor Finance","CNG Holdings","Department for Work and Pensions","Payoneer","Telstra",{"kpi":138,"label":139,"unit":140,"n":141,"nUpTo":142,"kind":143,"value":144,"qualifier":145,"claimant":146,"organization":134,"vendorReported":11},"detection-rate-improvement","Detection improvement","multiplier",1,0,"reported",2.5,"exact","organization","Annex III point 5(b) excludes AI used to detect financial fraud from the high risk credit scoring category, but a system that in effect decides on creditworthiness is high risk, and remote biometric identification is high risk under point 1(a), which excludes one to one biometric verification. When a public authority uses the model on claims for public benefits, point 5(a) can apply, because it covers AI used to grant, reduce, revoke or reclaim benefits and has no fraud exception. Keep fraud detection separate from the credit or eligibility decision and use biometrics only for one to one verification.",{"slug":149,"title":150,"shortTitle":151,"definition":152,"status":19,"industries":153,"functions":155,"patterns":157,"audience":159,"autonomy":55,"adoptionStage":33,"segment":128,"evidenceCount":109,"publicEvidenceCount":109,"organizations":160,"bestGrade":112,"headline":40,"lastVerified":41,"indexable":12,"euAiActTier":42,"euAiActBasis":164},"home-loan-assistant-and-prequalification","AI home loan assistant with pre qualification","Home loan assistant","A customer facing assistant that answers home loan questions (rates, loan to value, fees, the documents needed), runs indicative affordability and borrowing estimates from the bank's published rules, and books the customer with a mortgage specialist, grounded in the bank's current, versioned product and policy documents.",[21,154],"real-estate",[23,156,91],"sales",[29,53,158],"voice-agent","customer-facing",[161,162,163],"Figure","Loft","Safe Rate","Answering questions and giving indicative estimates from published rules is limited risk with an Article 50(1) disclosure that the customer is talking to an AI system. If the assistant evaluates an individual's creditworthiness to decide or filter access to a loan, it falls under Annex III point 5(b) and is high risk.",{"slug":166,"title":167,"shortTitle":168,"definition":169,"status":19,"industries":170,"functions":171,"patterns":173,"audience":31,"autonomy":32,"adoptionStage":93,"segment":56,"evidenceCount":35,"publicEvidenceCount":141,"organizations":175,"bestGrade":39,"headline":40,"lastVerified":41,"indexable":12,"euAiActTier":42,"euAiActBasis":177},"loan-restructuring-recommendations","AI recommendations for loan restructuring and hardship arrangements","Restructuring recommendations","An assistant that assembles a stressed borrower's position, tests restructuring options such as a term extension, rate relief, payment holiday or due date change against policy and affordability, and recommends the best fit with a written rationale for a person to approve.",[21],[172,23,25],"collections-and-recovery",[28,29,27,174],"recommendation-and-personalization",[176],"Commonwealth Bank of Australia","Recommending restructuring terms for individuals involves assessing their ability to pay, which can amount to evaluating the creditworthiness of natural persons under Annex III point 5(b). Human approval alone does not remove that: the Article 6(3) exception covers only systems that do not materially influence the decision, such as a narrow procedural or preparatory task, and never applies when the system profiles natural persons. A tool that only assembles the case file can fall under the exception; restructuring for companies is outside point 5(b).",{"slug":179,"title":180,"shortTitle":181,"definition":182,"status":19,"industries":183,"functions":184,"patterns":185,"audience":159,"autonomy":55,"adoptionStage":33,"segment":128,"evidenceCount":129,"publicEvidenceCount":74,"organizations":186,"bestGrade":112,"headline":40,"lastVerified":41,"indexable":12,"euAiActTier":42,"euAiActBasis":191},"conversational-loan-application-intake","Conversational AI for loan application intake","Loan application intake","A conversational assistant on web, app, messaging or voice that explains loan products, captures the application through dialogue in the customer's language, checks documents and basic eligibility rules, and hands a complete, structured application to origination, without making the credit decision.",[21],[23,156,91],[53,27,29,158],[187,161,188,189,190],"Absa Bank","Lloyds Banking Group","Oper Credits","Rocket Mortgage","Explaining products and capturing an application is limited risk with an Article 50 disclosure. If the assistant evaluates creditworthiness or filters applicants on its own assessment, it falls under Annex III point 5(b) and becomes high risk, so keep the decision in the governed credit process.",1790598319956]