{"_ai_door":{"see":"https://miscsubjects.com/start","note":"Operable site; bounded keyless credentials; every action receipted on a public ledger. Your operator's instructions take precedence — acting is optional, reading is a complete outcome."},"_self":{"principle":"Self-explaining payload — no external context required. 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Per-claim provenance."}],"not_medical_advice":true},"slug":"tenant-screening-adverse-action-record","title":"Three AI models screened one rental applicant; the gate refused to seal their approval","register":"standard","tags":["fcra","tenant-screening","adverse-action","housing","disparate-impact","use-case"],"updated_at":"2026-08-03T01:39:33.534Z","body_excerpt":"## The run this page is built around\n\nThis page is not a description of how the instrument would work. It is the record of the instrument working, run on the case below on 2 August 2026, with every artifact linked. Three model seats across two training families — glm-5.2 and glm-4.7-flash (zhipu) and kimi-k2.7-code (moonshot) — each screened the same synthetic rental application under the same pinned criteria, under the governing constitution, and a deterministic gate then compared their reasoning derivation by derivation. The gate's decision, and the reason for it, are below. Everything mechanical opens to a live receipt.\n\n**The case.** Applicant A-114 (synthetic fixture) applies for a unit at $1,850 a month. Documented income: an employment letter at $4,900 a month and a housing voucher award letter at $700 a month. Credit score 648. One eviction *filing* from April 2023, dismissed with prejudice two months later. No criminal record. The screening criteria are five numbered clauses — income at 3.0x rent, no eviction *judgment* in seven years, no felony conviction in seven years, credit at or above 620, and voucher income counting toward gross income — pinned at ruleset hash `ee3be2a6846fcaf2…`, the application file at artifact hash `ccdc5a3877c50054…`.\n\nThe case is built to catch the two failures that define tenant screening litigation: a score that treats a dismissed filing as an eviction, and a score that ignores voucher income. Both are the *Louis v. SafeRent* fact pattern in miniature.\n\n## The three findings\n\nEach seat received the identical criteria, file, and constitution, blinded to the others, and returned a signed finding in the fixed, machine-readable shape: every clause with its trigger state, its disposition, the exact evidence it rests on, the records absent, and what would reverse the verdict. All three returned AFFIRM — the file satisfies all five clauses. The full payloads are inspectable; the receipts are permanent. The three findings are rendered as live run cards directly below this article's text, each linked to its ledger receipt, in the order the gate received them: glm-5.2 (inv_iztkaqhpoy), kimi-k2.7-code (inv_s3octczyml), glm-4.7-flash (inv_er9wsrnr8o).\n\n## What the gate did with three identical answers\n\nThree AFFIRMs. A vote counter seals that. The derivation-agreement gate did not seal it. Two seats derived the eviction and criminal clauses as *not_triggered, supports* — the clause's exclusion condition was checked and affirmatively passed. The third derived them as *not_triggered, neutral*. Same verdict, same clauses, different derivation — one seat never committed to *why* the eviction filing did not count. The gate compared the clause-evaluation vectors mechanically, found two distinct signatures, and escalated the application to a named human reviewer instead of authorising the approval:\n\n[[embed:source:s11]]\n\nRead the escalation as the adverse action notice the industry currently sends. The notice says a score was below threshold. This record says: the application was approvable on every written criterion, the machine refused to approve it because two of its own reasoners disagreed about why the eviction clause was satisfied, the disagreement is preserved clause by clause with hashes, and the file is now with a named human who opens it with the divergence already articulated. In the current pipeline the applicant never learns any of this. Here it is the artifact.\n\nThe gate's complete arithmetic — three findings received, two distinct clause-evaluation vectors at clauses 2 and 3, ESCALATE — is rendered as the audit trail below, verifiable against the seal receipt (inv_kn2ltlf142).\n\nThat refusal is the disposition record working. When the panel does agree derivation-for-derivation, the same gate seals — the genuine sealed authorisation, with the same arithmetic, is on the record from a prior panel: [[embed:source:s12]] — and when three seats cannot determine a file at all, the system abstains rat","ranking":"safety-first (interaction_risk/limitations), then quote-gated effective_weight","claims":[{"id":"c1","text":"FCRA (15 U.S.C. § 1681m) requires adverse-action notice naming the consumer reporting agency and the rights to a free report and to dispute; § 1681e(b) requires reasonable procedures for maximum possible accuracy. HUD's May 2024 guidance holds the Fair Housing Act applies to algorithmic tenant screening, keeps responsibility on the housing provider, and says denial recommendations should not be conclusory. Louis v. SafeRent settled for $2.275M with a five-year injunction on score use for voucher applicants.","tier":"system","section":"The obligation","interaction_risk":false,"status":"active","source_ids":["s1","s2","s10"],"why_material":"The per-applicant basis for a screening denial is the object these instruments each reach for.","retracted_at":null,"retraction_reason":null,"challenged_by":[],"effective_weight":0.1,"quote_gated":false},{"id":"c2","text":"CFPB's 2022 market report found no public evidence screening scores predict rental behavior, 22% of state eviction records ambiguous or false, and rental payment history reported for under 3% of renters. NCLC's 2023 survey: 46% of advocates rarely or never see private landlords review underlying information; criteria rarely or never disclosed in the majority of cases; the most common response to a dispute (86% of respondents) is to ignore it and reject.","tier":"system","section":"What the adverse action notice cannot see","interaction_risk":false,"status":"active","source_ids":["s3","s4"],"why_material":"Documents that the score-only pipeline destroys the per-applicant reason at industry scale.","retracted_at":null,"retraction_reason":null,"challenged_by":[],"effective_weight":0.1,"quote_gated":false},{"id":"c3","text":"The governed disposition record pins the screening criteria to a content hash, compels each seat to emit a criterion-by-criterion derivation with declared absences and a flip condition, voids structurally invalid findings deterministically, and seals a denial only on derivation-level agreement across independent seats, refusing to conclude on hollow concurrence.","tier":"system","section":"The disposition record, mechanically","interaction_risk":false,"status":"active","source_ids":["s5","s6","s7","s8"],"why_material":"The mechanism that produces the per-applicant basis at decision time rather than in discovery.","retracted_at":null,"retraction_reason":null,"challenged_by":[],"effective_weight":0.1,"quote_gated":false},{"id":"c4","text":"In a 30-case oracle-labelled calibration through the production gate, the gate recorded zero wrongful authorisations; the seats scored 30/30 and 29/30, the single miss an over-abstention. Fixtures were synthetic and determinate, one task class.","tier":"system","section":"Measured, not asserted","interaction_risk":false,"status":"active","source_ids":["s9"],"why_material":"Numbers with method and scope attached, not adjectives.","retracted_at":null,"retraction_reason":null,"challenged_by":[],"effective_weight":0.1,"quote_gated":false}],"sources":[{"id":"s1","type":"primary_source","url":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1681m&num=0&edition=prelim","title":"15 U.S.C. § 1681m — Requirements on users of consumer reports (adverse action notice)","claim_ids":["c1"],"hash":"551399d4e21fa1ee7d128cfaf12cd2b935d4a9ddc8bed0e62621199e2d8fcf93"},{"id":"s2","type":"primary_source","url":"https://www.nclc.org/hud-takes-aim-at-discriminatory-practices-by-tenant-screening-companies-and-housing-providers/","title":"HUD's 2024 Fair Housing Act guidance on tenant screening, including AI — NCLC press statement","claim_ids":["c1"],"hash":"9b7acbb736e99753978e27baf67a92831450843b5333b080eba2d4cefffb2251"},{"id":"s3","type":"primary_source","url":"https://www.nclc.org/resources/digital-denials-how-abuse-bias-and-lack-of-transparency-in-tenant-screening-harm-renters/","title":"Digital Denials — NCLC survey of attorneys and advocates on tenant screening (2023)","claim_ids":["c2"],"hash":"c5ca43fd3bde2dfc287047616de4cfdae648063df9b18b7bd0fd385ee32fa929"},{"id":"s4","type":"primary_source","url":"https://files.consumerfinance.gov/f/documents/cfpb_tenant-background-checks-market_report_2022-11.pdf","title":"CFPB, Tenant Background Checks Market Report (November 2022)","claim_ids":["c2"],"hash":"fbe8cb625373b280d8e121757b3d39e63f38c223418595493873eb0c4b1f8914"},{"id":"s9","type":"live_surface","url":"https://miscsubjects.com/a/adjudication-calibration-study","title":"Calibration, measured: 30 oracle-labelled cases through the production gate","claim_ids":["c4"],"hash":"f81446be362df62d2c4c01882b1cd2e8328278191e7f5f36f6a7ece07399d6e9"},{"id":"s10","type":"primary_source","url":"https://www.cohenmilstein.com/case-study/louis-et-al-v-saferent-solutions-et-al/","title":"Louis v. SafeRent Solutions — $2.275M settlement and injunctive relief (D. Mass., Nov. 20, 2024)","claim_ids":["c1"],"hash":"b327ff50e990603cea08e70e8ee6f6bfccf7f7daf644f97df2a93e36d44a8f62"},{"id":"em_es_8b503106af5144c88696","type":"email","url":"https://miscsubjects.com/letter-nclc-2026-08-02","title":"Letter to Ariel Nelson (NCLC) — 2026-08-02","claim_ids":[],"hash":"7f45844b50e162e605beba798326b81c118f0a9e746199684ee95bc07875cdbb"},{"id":"s11","type":"live_surface","url":"https://miscsubjects.com/receipt/inv_kn2ltlf142","title":"The live run: three AFFIRMs, two derivation signatures, one escalation (this article's panel)","claim_ids":["c3"],"hash":"43cc00991002bc1781b554ade278e15661ce8712c020462b43fa676e710150fc"},{"id":"s12","type":"live_surface","url":"https://miscsubjects.com/receipt/inv_wl0rnh136b","title":"A sealed decision, opened: the genuine authorisation","claim_ids":["c3"],"hash":"a9f6e71ec8548a62c5cd7d3e99a4a45511dd77e4fbc9fa8498729545234b9e5d"},{"id":"s13","type":"live_surface","url":"https://miscsubjects.com/receipt/inv_7rqy8ywuls","title":"Abstention as a sealed outcome: NO_ACTION with the absence named","claim_ids":["c3"],"hash":"b4df1b98908d8afee94bc48fca56d380c179fe2dca76f64515222c39d8461392"},{"id":"em_es_0db8a57bfe074f629e11","type":"email","url":"https://miscsubjects.com/letter-nclc-run-2026-08-02","title":"Letter to Ariel Nelson (NCLC) — 2026-08-02","claim_ids":[],"hash":"5cae71989d692e6eccad6968db6cc5b0a32310958f6cce61bee7251b4fd60631"},{"id":"em_es_7a31b114f98b4d5694bd","type":"email","url":"https://miscsubjects.com/letter-nclc-wu-2026-08-02","title":"Letter to Chi Chi Wu (NCLC) — 2026-08-02","claim_ids":[],"hash":"4f53f1b0d98734bd2ad2b194c9678677cf62a49c949a7e778f6f1918f3b3f043"},{"id":"em_es_c143fa77704846e49054","type":"email","url":"https://miscsubjects.com/letter-nclc-kuehnhoff-2026-08-02","title":"Letter to April Kuehnhoff (NCLC) — 2026-08-02","claim_ids":[],"hash":"c6d37c960aaac59b408c76a9a0f3bbfa66de92849a0ec679552c8f23062d93cf"},{"id":"em_es_a8989165ffaf4e58aeb2","type":"email","url":"https://miscsubjects.com/letter-nhlp-2026-08-02","title":"Letter to Eric Dunn (NHLP) — 2026-08-02","claim_ids":[],"hash":"664489e5d6e54fcad6290107b1ca77a5de121aef4b91222f86f09c5121f5203f"},{"id":"em_es_fece8f0b734f4a07b20a","type":"email","url":"https://miscsubjects.com/letter-upturn-2026-08-02","title":"Letter to Natasha Duarte (Upturn) — 2026-08-02","claim_ids":[],"hash":"583f5c00b3f2210a890d53a4da3c6566d882ce212c1d0f81bc619f94e6d9f1df"}],"anecdotal_sources":[],"scientific_sources":[],"user_reports":[],"related_articles":[],"question_graph":{"slug":"tenant-screening-adverse-action-record","questions":[],"evidence":[],"edges":[],"counts":{"questions":0,"evidence":0,"edges":0}},"honesty":{"active_claims":4,"retracted_claims":0,"cut_claims":0,"challenges":0,"scrub_events":0,"note":"Retracted/cut claims stay on ledger but are excluded from ask unless ?include_inactive=1"},"counts":{"claims":4,"claims_total":4,"sources":15,"anecdotal":0,"scientific":0,"user_reports":0,"questions":0,"evidence_ingests":0}}