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Colorado’s proposed ADMT rules could expand AI compliance for lenders
The proposed requirements would take effect for covered consequential decisions starting Jan. 1, 2027, with lenders facing new documentation, disclosure, and human review obligations.
Colorado lawmakers have released proposed rules for automated decision-making technology, or ADMT, that would add new documentation, disclosure, and human review obligations for businesses where the technology materially influences decisions affecting consumers, including mortgage lending.
According to HousingWire, Senate Bill 26-189 would apply to consequential decisions made on or after Jan. 1, 2027, and defines ADMT as technology that processes personal data to generate information used to make, guide, or assist consequential decisions.
The Mortgage Bankers Association said the proposal needs refinement before the effective date, arguing that it does not clearly define what counts as ADMT or what constitutes a consequential decision, which could leave creditors uncertain about which processes trigger the law.
HousingWire also notes the MBA supports combining ADMT disclosures with adverse-action notices required under the Equal Credit Opportunity Act or Fair Credit Reporting Act, and it raised concerns about when creditors could deny human review requests as commercially unreasonable, while also calling for clearer lines of responsibility between ADMT developers and deployers.