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AI Impact Assessment Example for Credit Unions

A worked example assessing an automated personal loan decision model, from purpose and data to risks, controls, and approval.

Financial Services · Credit Unions and Lenders · Prepared by the Cogent Assurance team

Aligned withNIST AI RMF · Map and MeasureISO/IEC 42001 · AI system impact assessment

The short answer

An AI impact assessment documents what an AI system does, who it affects, what could go wrong, and which controls reduce that risk, before the system goes live and at each major change. For a credit union, the systems that most need one are those that affect credit decisions or account access, such as an automated personal loan decision model.

Worked example: automated personal loan decisions

System
Vendor-provided model that approves, denies, or refers personal loan applications under $10,000
Purpose
Faster decisions for small personal loans and consistent application of credit policy
Members affected
All personal loan applicants, about 4,000 a year
Data used
Credit report, income, existing relationship, and application data
Role in decisions
Approves or refers automatically; a loan officer reviews every referral and may override
Risk tier
High: directly affects credit decisions
Laws involved
Regulation B, Fair Credit Reporting Act, Gramm-Leach-Bliley Act, state laws for members in other states
Key risks
Discriminatory effects, adverse action reasons that do not reflect the model’s actual drivers, data errors, vendor model changes
Controls
Fair lending testing before launch and quarterly, reason code validation, monthly sampling of decisions, contractual notice of model changes
Residual risk
Medium after controls
Approved by
AI governance committee, with the decision reported to the board
Next review
Twelve months, or sooner if the model or data changes

Risk before and after controls

Before controlsAfter controls

Fair lending
85
40
Accuracy
70
35
Privacy
55
25
Vendor change
60
30
Member impact
80
45

Scores out of 100, illustrative.

Steps in an assessment

  1. 1DescribeSystem, purpose, users, and decisions
  2. 2Map dataSources, use, and protection
  3. 3Identify risksFairness, accuracy, privacy, security
  4. 4Set controlsA tested control for each risk
  5. 5DecideApprove, condition, or decline

Why assessments are becoming standard

Frameworks such as the NIST AI Risk Management Framework and ISO/IEC 42001 expect organizations to assess AI systems before deployment, and state laws increasingly require documentation for automated decisions. A completed assessment is also the clearest evidence an examiner can review.

Frequently asked questions

Which AI systems need a full impact assessment?

Start with high-risk systems: anything that affects credit decisions, pricing, or account access. Medium-risk systems can use a shorter version.

Who should complete the assessment?

The system owner leads it, with input from compliance, information security, and the vendor. The AI governance committee reviews and approves it.

More Guides for Credit Unions and Lenders

Sources

How this guide is built

Built from primary sources: statutes, regulations, standards, and agency guidance. Our team reviews each industry’s legal summary every quarter and updates guides when requirements change.

Cite this guide

Cogent Assurance. (2026). AI Impact Assessment Example for Credit Unions. Cogent Assurance Resource Center. https://cogentassurance.com/resources/ai-impact-assessment-credit-unions

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This guide is general information for planning purposes. Laws and guidance change, so confirm current requirements before acting. It is not legal advice. For legal advice about your organization, consult a licensed attorney.

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