Underwriters and collections staff first, because they will sign the decisions that most affect borrowers. A lender should certify those reviewers before the agent drafts a credit decision or a collections letter, teach them to state reasons from the agent's draft, and keep disbursement with a certified person until every check has evidence behind it.
Why do lenders need to train this way?
Lending decisions carry legal and personal weight. In the EU, creditworthiness assessment and credit scoring of natural persons are listed as high-risk under the AI Act, with human oversight expected under Article 14. In the US, ECOA and Regulation B require specific reasons when credit is denied, including when a model is used. Data protection law restricts decisions with significant effects made solely by automated processing.
All of that lands on the reviewer. An underwriter who approves an agent's decline must be able to say why, in terms a borrower and a regulator would accept. A collections agent who sends an agent-drafted letter must know whether the borrower is in difficulty. Neither skill comes from a general AI course.
What order should training follow?
| Order | Group | What they must be able to do |
|---|---|---|
| 1 | Credit committee and senior management | Decide which capabilities the agent may target and at what depth; read the record |
| 2 | Underwriters | Judge an agent-drafted decision, verify income and affordability evidence, state reasons |
| 3 | Collections and customer support | Recognise financial difficulty and vulnerability in a held case; decline drafts that miss it |
| 4 | Team leaders | Calibrate decisions across underwriters; watch for drift in approval rates |
| 5 | Credit risk and model risk | Test whether the agent's decisions stay consistent across applicant groups |
| 6 | Builders | Write the agent's brief and bounds after time on the held queue |
The case for training reviewers even before choosing the agent is made in train the reviewers before you buy the agent.
What must underwriters learn specifically?
Evidence by class. An applicant's stated income is declared. A bank statement pulled from the applicant's account through a connection is from a system of record. A payslip uploaded as a picture is declared until verified. An employer letter emailed in is external. Affordability should rest on the strongest evidence available, and the underwriter must see the class of each figure in the draft.
Reasons that survive challenge. "Declined: verified income does not cover existing commitments plus the new repayment" is a reason. "Declined: score below threshold" is not enough for a borrower, a complaints body or, in the US, the adverse action notice.
The decisions the agent refuses. A lender's own limits should refuse some actions to the agent outright, such as declining an applicant who disclosed a vulnerability, and hold others. Reviewers need to know which, so a refusal is routed rather than overridden.
What stays with a person?
The agent may read application data and credit files (depth 1), draft decisions, affordability summaries and collections letters (depth 2), and, once certified, approve small, clear applications within the lender's limits (depth 3). Declines, forbearance arrangements, cases with a vulnerability flag, and disbursement of funds stay with a person. Disbursement is depth 4, because money leaving the lender is hard to recover, and it needs a certified, current approver.
What should be proven before widening?
Before an agent approves anything on its own, a lender should see: the agent certified at that depth on its own past applications; underwriters' practicum decisions with no missed red line, such as approving on unverified income; a model risk review of consistency across groups; and a named credit owner's signed decision. If outcomes drift during the first weeks, the capability returns to depth 2 until the cause is understood.
An example
Take a hypothetical consumer lender with 25 underwriters and 30 collections staff. All take the vocabulary course in the first fortnight. Ten underwriters become certified reviewers while the agent drafts personal loan decisions in shadow for four weeks; every decline in that period is reviewed twice. The collections team trains on agent-drafted letters, with a red line around anyone who has mentioned illness or job loss. After a credit risk review, the agent approves small loans with verified income at depth 3. Declines and disbursement stay with people. The AI agent training plan template for lenders lays out those weeks; utilities, which also deal with customers in arrears, follow a related path in how utilities should train staff.
Questions people ask
Can a lender use agents before underwriters are certified?
At depth 1 or 2, with every decision made by a person, yes. See can lenders use AI agents before staff are trained.
Do collections staff need the same training as underwriters?
The same reviewer core, with different red lines. Underwriters focus on evidence and reasons; collections staff focus on difficulty and vulnerability. Pryme Intelligence Academy sets module tests in each learner's role for that reason.
What do lenders get wrong?
Training underwriters on approvals but not on declines. More in what lenders get wrong about AI agent training and the guide to training teams for AI agents.