What does an AI adverse-action claim cost your firm?

Six inputs. Two minutes. IFRS 9 / ASC 450 defensible methodology.
Used by general counsel to quantify §1002.9 reserve exposure.

LENDING

HR / AEDT

HEALTHCARE

Every AI credit denial needs a specific, model-derived reason under §1002.9. Earnest Operations paid $2.5M when they didn't. AOD ¶71 now mandates an internal algorithmic oversight team at every AI lender under consent order.

AI Decisions per Year 500,000

1K5M

Adverse-Action Rate 18%

1%60%

Primary Enforcement Jurisdiction 1.5×

⚠ NJ: AG + DCR Director + private complainants all have standing (Morgan Lewis confirmed). Highest enforcement surface of any US jurisdiction.

Evidence Maturity (1=none → 5=full DPR) Logs only

No evidenceFull DPR

Months since last model validation 14 months

Just tested3 years ago

Your Reserve Exposure

Estimated §1002.9 Reserve Exposure (Before GateFrame)

—

Reserve After GateFrame DPR Deployment

—

GateFrame eliminates adverse-action notice accuracy as a failure mode (the specific Earnest violation).

Reserve Reduction

—

GateFrame ACV

$80K

ROI Multiple

—

ASC 450-20 / IFRS 9 Contingent Liability Framework

GateFrame eliminates the adverse-action notice accuracy failure mode cited in Earnest AOD. Proxy-discrimination and training-data-lineage claims are not modeled here.

Get the audit-defensible PDF methodology

Includes calculation framework, ASC 450 / IFRS 9 citations, Earnest AOD ¶71 remediation brief, and a 30-minute architecture review offer.

✓ PDF on its way

For a 30-minute architecture review:
shankar@gateframe.io — subject: Reserve Calculator → 30-min review

Anchor case: Earnest Operations LLC — $2.5M settlement (MA AG, July 10, 2025). Violation: inaccurate AI adverse-action notices failing to state specific reasons. AOD ¶71 mandates an internal algorithmic oversight team responsible for fair-lending testing and tamper-evident decision records.
NJ: N.J.A.C. 13:16 (eff. Dec 15 2025) — private-party standing confirmed (Morgan Lewis).