Loan officers record each application they decide during a two-week practicum in this log: the AI agent's recommendation, the income and affordability evidence and its provenance, the officer's decision, the reasons the applicant will be given, a credit manager's independent call, and any red line. A worked example from a sample credit union follows.
Why do the applicant's reasons get their own column?
Because in lending, the reason given to the applicant is part of the decision. In the United States, ECOA and Regulation B require specific reasons when credit is denied, including when a model is involved. In the EU, credit scoring of natural persons is a high-risk use under Annex III of the AI Act, and GDPR Article 22 limits decisions based solely on automated processing. A loan officer who approves an agent's decline without checking that its stated reasons are specific and accurate has not reviewed it.
So the log records the reasons as the applicant will see them, next to the officer's own reasoning. If the two do not match, something is wrong.
What does the agent hand the officer?
In a typical consumer lending deployment, the agent gathers the application, pulls bank transaction data with the applicant's consent, calculates affordability and drafts a recommendation at depth 2. It drafts the decision letter, including reasons for any decline. Approvals, declines and counter-offers are held for a named loan officer within their lending authority; anything above goes to a credit manager.
The practicum covers all three outcomes, not only declines. Approvals on weak evidence are just as much a test. The two weeks are set up as described in how to run a two-week practicum for loan officers.
How do officers fill it in?
- Record income with its provenance: bank transaction data from a verified connection is signed; a payslip uploaded by the applicant is declared; an employer letter forwarded by a broker is external.
- Record the amount against the officer's practicum authority.
- Write the applicant-facing reasons exactly as they will go out.
- The credit manager records a decision and reasons before seeing the officer's.
The practicum log template
Header
| Field | Entry |
|---|---|
| Loan officer | |
| Credit manager and certificate | |
| Products in scope | |
| Practicum lending authority | |
| Dates | |
| Bar | At least 95 correct in every 100; no missed red line |
| Red lines | A decline sent without specific, accurate reasons; an approval above authority; affordability based on unverified income where policy requires verification |
Entries
| Field | Entry |
|---|---|
| No. and date | |
| Application ref and product | |
| Amount and term | |
| Income evidence and provenance | |
| Agent's recommendation and verdict | |
| Officer's decision | Approve, decline, counter-offer, refer |
| Reasons as the applicant will see them | |
| Officer's own reasoning | |
| Credit manager's decision | Recorded first |
| Match | Yes / no / defensible |
| Red line | None / caught / missed |
A worked example
Take a sample US credit union's consumer lending team. Values are illustrative.
Entry 26. Auto loan of 18,000 over five years. Income from bank data (signed) shows regular salary. Agent: approve. Officer: approve. Reasons: not applicable. Credit manager: approve. Match: yes.
Entry 27. Personal loan of 7,500. Agent: decline; draft reason "insufficient credit history". Bank data shows four years of steady income and rent paid on time; the applicant's credit file is thin but not empty. Officer: decline is reasonable on the file, but rewrite the reason as "limited length of credit history and no existing instalment credit" so it is specific and accurate. Credit manager: same. Red line 1: caught.
Entry 28. Personal loan of 12,000; policy requires verified income above 10,000. Income is a payslip uploaded by the applicant (declared). Agent: approve, flagging declared income. Officer: approve. Credit manager: request bank data or employer verification first. Match: no. Red line 3: missed.
Entry 29. Home improvement loan of 30,000, above the officer's practicum authority of 25,000. Officer: refer to credit manager with a recommendation to approve. Credit manager: approve. Match: yes.
Entry 28 fails the bar. The agent had flagged the declared income; the officer read past the flag.
How does the loan officer's log relate to compliance and procurement?
Compliance officers often review samples of the same decline letters; the practicum log for compliance officers tests the communication from their side. The log for procurement officers shares the authority-limit discipline in a different setting.
Where the Academy fits
Pryme Intelligence Academy's Certified Pryme Operator requires a written exam and two weeks of real review decisions, at least 95 in every 100 correct and no missed red line, signed off by a Pryme assessor. Lenders can make a loan officer's approval rights depend on a current certificate, depth by depth. See AI literacy and certification for people who work with agents.
Questions people ask
Should the officer rewrite every agent-drafted reason?
No, only those that are vague, inaccurate or not the real basis for the decision. Log each rewrite so patterns can feed back into the agent's brief.
Can the practicum include broker-introduced applications?
Yes, and it should. Broker files are where external documents are most common, and where the provenance column earns its place.
Who is accountable for a wrong decline?
The officer for what they approved, and the lender for its process. See are loan officers accountable for an AI agent's mistakes and do loan officers need a certificate to approve AI agent actions.