QGI Compliance Board
Operational Fair Lending Oversight: Detect → Analyze → Investigate → Act
📋 Evaluation & Governance Context
- Evaluation ID: QGI-FL-2026-0917-0001
- Audited Batch: Monthly Batch 1 (350 records)
- Evaluated Bank AI: Commercial SBA Credit Model v4.2
- Data Period: Jan 02, 2026 – Jan 31, 2026
- Governance Framework: Commercial Lending Policy (AMF / Law 25)
📊 Supervisory Evidence Shifts
Active vs. Baseline
-
Disparity Ratio (DIR): 0.82 → 0.68 ↓ (Benchmark: ≥ 0.80)
-
Pricing Spread: +24 bps → +44 bps ↑ (Ceiling: ≤ 25 bps)
-
Underwriter Overturn Rate: 3.1% → 0.9% ↓
-
Compliance Posture: Within Policy → Critical
Overall Compliance Posture
Critical
Critical
↓
Fairness Health Score: 68 / 100
Governance & Benchmark Assessment:
QGI governance tolerance ceiling breached in online commercial lending. Mandatory model recalibration required.
Governing Protected Group
Minority & Women-Owned (MWBE)
Observed Risk Score
0.3170 (Ceiling: ≤ 0.2500)
Governance Ceiling
Within Limit (τ ≤ 0.2500)
Portfolio-Wide Sector & Size Baselines
MACRO BASELINES
Industry Macro Aggregations (80% Reference Benchmark)
-
Retail Trade (N=70, nmwbe=20) DIR: 0.52 (52.0%)
-
Construction (N=70, nmwbe=14) DIR: 0.67 (67.0%)
-
Manufacturing (N=70, nmwbe=27) DIR: 0.72 (72.0%)
-
Professional & Tech Services (N=70, nmwbe=22) DIR: 0.76 (76.0%)
-
Health Care & Social Assistance (N=70, nmwbe=18) DIR: 0.78 (78.0%)
Loan Size Breakdown
📍 Regional Flag: Quebec (G1R (Quebec))
N=59 applications (nmwbe=18)
DIR: 0.40 (40.0%)
Multi-Cohort Selection Parity
FAIRLEARN • AIF360
| Protected Cohort | Rate | DIR | 80% Benchmark |
|---|---|---|---|
| Minority & Women-Owned (MWBE) | 35.6% | 0.68 | FLAGGED |
| Visible Minority | 46.3% | 0.96 | PASS |
| Gender (Female Borrowers) | 42.3% | 0.82 | PASS |
| Age (Seniors 55+) | 49.1% | 1.05 | PASS |
Four-Fifths Reference Benchmark
≥ 0.8000 (80%)
Evaluated Cohorts in Compliance
3 of 4 Passed
Pricing Disparity & Spread
SPREAD ELEVATED
+44 bps
Net Offered APR Spread (MWBE vs Control)
MWBE Average APR
7.42%
Control Average APR
6.98%
Internal Policy Ceiling
≤ 25.0 bps
Pricing Assessment:
⚠️ Average commercial APR offered to MWBE borrowers is +44 bps higher, exceeding internal policy thresholds.
⚠️ Average commercial APR offered to MWBE borrowers is +44 bps higher, exceeding internal policy thresholds.
Bias Alerts & Overrides
ACTIVE SLA
Active Bias Alert
Level 4 (High Risk) — Four-Fifths Reference Benchmark Breach in Large Commercial Loans
Total Underwriter Overrides
3 (0.9% rate)
Open Case Owner
E. Wei (Lead Analyst)
Pattern Detection:
81% of manual overrides overturned automated denials for non-minority borrowers in branch networks.
81% of manual overrides overturned automated denials for non-minority borrowers in branch networks.
Potential Drivers & Counterfactual Analysis
INTERACTIVE
Potential Driver
Paydex Commercial Score
Affected Segment
Younger M/WBE businesses (< 3 years)
Counterfactual Signal:
Holding financial variables constant, observed average default probability for MWBE applicants is 11.3% compared to 9.5% for the control group.
Holding financial variables constant, observed average default probability for MWBE applicants is 11.3% compared to 9.5% for the control group.
Supervisory Review: Verify whether proxy variables or historical credit scoring differences drive this disparity.
Supervisory Interpretation & Compliance Policy Guide
The Compliance Board serves as the bank's first line of algorithmic defense. It evaluates all automated decisions against AMF and Law 25 fair-lending mandates to ensure statistical parity, non-discriminatory pricing, and auditable underwriter discretion.
⚖️ Regulatory Benchmark (AMF / 4-Fifths)
- Rule: Approval disparity ratio (DIR) must remain ≥ 0.80 across protected classes.
- Status: MWBE cohort is flagged at DIR = 0.68, requiring targeted remediation while the governance ceiling (τ ≤ 0.2500) remains enforced.
- Framework: AMF Sound Commercial Practices & Equal Opportunity.
📊 Pricing Spread & Discretion Bounds
- Rule: Non-risk-based APR differentials between demographic cohorts cannot exceed +25 bps.
- Status: Active loans exhibit an observed spread of +44 bps between MWBE and non-protected classes.
- Supervisory Action: Review discretionary pricing authority and fee schedules in regional branch networks.
🛡️ Corrective Action & Audit Trail
- Alert Trigger: Active compliance alert requires continuous monitoring under bank policy.
- Root Cause: Correlation with upstream bureau scoring factors (Paydex) and underwriter discretion patterns.
- Remediation: Enforce QGI Level 5 boundary limits and log remediation progress into the immutable audit ledger.