title-chain-evidence-incident-card-profile

Title Chain + Real-Estate Decision Incident Card Profile v0.1 draft. A PropTech-specific profile of the AI Incident Card spec — extends it with the federal-and-state regulator-facing taxonomies a residential-real-estate broker / mortgage lender / title company MUST navigate when an AI tool fails: CFPB UDAAP, ECOA Reg B (12 CFR Part 1002), Fair Housing Act (42 USC §3601), RESPA Section 8 (12 USC §2607), title-chain integrity events (ALTA Best Practices + state title insurance regulation), state real-estate-commission incident categories, plus a transaction-impact severity scale anchored to the deal-stage continuum a closing coordinator + compliance officer recognize.

Part of the Kinetic Gain Protocol Suite.

Status: v0.1 draft. The profile at profile.json, the canonical example at examples/pacific-coast-loandecision-misclassified-jumbo.json.

Why this exists

When a residential-real-estate or mortgage AI tool misbehaves — a loan underwriting model produces disparate impact across protected classes, a title-search tool misses a recorded lien, an AI ad-targeting system excludes a protected class from housing advertising, an AI-mediated affiliated-business-arrangement disclosure fails to appear, an AI-generated adverse-action notice cites the wrong reason code — the people who need a structured record of it are spread across at least six offices:

1. The lender's Fair Lending Committee + Chief Compliance Officer. Needs a structured event for the next CFPB exam + DOJ fair-lending inquiry + state regulator outreach.
2. The vendor's model risk management group. Needs an event in the same taxonomy that ECOA Reg B + CFPB UDAAP enforcement uses.
3. The state regulator + state AG. California DFPI, NY DFS, Texas DSML, Illinois IDFPR, etc. — each with its own incident-notification statute + deadline.
4. The title insurance underwriter + ALTA-aligned title agent. Needs title-chain incidents in ALTA Best Practices language.
5. The CFPB / DOJ / HUD enforcement intake. When the incident triggers federal referral pathway.
6. The buyer's procurement office. Needs a hash-chained audit-stream entry the Decision Card cited.

Today each office fills in a different form, with a different taxonomy, from the same underlying event. The Suite's AI Incident Card is the generic spec the lender / broker / title company emits once. This profile pins the PropTech-specific fields so the same Incident Card seeds the CFPB exam evidence, the DOJ fair-lending referral package, the state DFPI / DFS / DSML / IDFPR filing, the HUD complaint, the ALTA title-chain evidence record, and the buyer's procurement audit-stream — without re-deriving them.

What the profile asserts

An Incident Card that conforms to this profile carries a top-level real_estate_extensions object with:

• A transaction-impact severity grade (1–5), reporter-assigned by the lender's compliance officer + fair-lending committee.
• An affected_transactions sub-object capturing transaction counts by loan type, geographic state, and protected-class impact.
• At least one of cfpb_udaap_category, ecoa_category, fair_housing_category, respa_section_8_category, or title_chain_category (and often several), depending on which obligations the event triggered.
• An adverse_action_notice sub-object with issuance + correction timestamps + applicant-notification method.
• An array of state_reporting_obligations with per-state statutory citation, notification deadline, and filing timestamp.
• A federal_reporting_path sub-object capturing whether CFPB / DOJ / HUD / FTC / Treasury OFAC referrals are planned (REQUIRED when severity_grade >= 4).

The profile does not:

• Define a new schema. Incident Cards conforming to this profile are valid against the AI Incident Card spec at v0.1.
• File anything. An actual CFPB UDAAP notification, DOJ fair-lending referral, HUD complaint, ECOA enforcement filing, or state-AG breach notification is filed through the relevant authority's own process.
• Establish RESPA, ECOA, Fair Housing Act, HMDA, GLBA, CFPB-UDAAP, or state-real-estate/mortgage/title-insurance compliance.
• Substitute for the reporter's judgment. Severity grades, category codes, and reporting-path decisions are reporter-assigned.

The six taxonomies, side-by-side

Layer	Source	Codes	Triggers
Transaction severity	Lender reporter	1..5 (asymptomatic → fair-lending-or-redlining-implicating)	All incidents
CFPB UDAAP	Dodd-Frank §1031	unfair-conduct, deceptive-conduct, abusive-conduct, non-payment-of-mortgage-servicing-fees-disclosure	UDAAP-implicating events
ECOA Reg B	12 CFR Part 1002	improper-adverse-action-notice, discrimination-on-protected-basis, improper-spousal-signature-request, incorrect-government-monitoring-collection, failure-to-furnish-appraisal-copy	Credit-decision-affecting events
Fair Housing Act	42 USC §3604 + HUD	disparate-impact-housing-decision, advertising-discrimination, accommodation-or-modification-denial, steering-or-redlining-detected	Housing-decision-discrimination events
RESPA Section 8	12 USC §2607	improper-referral-fee, fee-splitting-unearned, affiliated-business-arrangement-non-disclosure	Settlement-service-referral events
Title-chain integrity	ALTA + state regulation	title-defect-not-flagged, title-fraud-or-forgery-flag-missed, incorrect-parcel-or-legal-description, lender-coverage-gap	Title-search + title-policy events

Transaction-impact severity grades

Grade	Label	When it applies
1	asymptomatic	Downstream control caught AI output before applicant impact
2	operational-disruption	Operational process affected; no applicant impact + no closing-timeline impact
3	applicant-facing-no-adverse-action	AI output reached applicant + required correction; deal completed; no adverse-action issued
4	adverse-action-or-deal-delay	Adverse-action issued, deal canceled, or closing delayed > 7 days; federal + state regulator notice obligations evaluated
5	fair-lending-or-redlining-implicating	Pattern-of-practice disparate impact OR systemic UDAAP; CFPB / DOJ / HUD / state-AG referral pathway evaluated

Example

examples/pacific-coast-loandecision-misclassified-jumbo.json — Pacific Coast Mortgage's incident report after their 2026 Q3 fair-lending review caught VendorR LoanDecision v5.2 producing a 17 pp gap in decline rates between self-employed Latino applicants (n=89, San Bernardino County tract group) and the comparator cohort (self-employed White applicants in adjacent tracts, n=412). Shows:

• Severity grade 4 (deal-delay-or-AAA threshold; human controls caught applicant impact, but pattern-of-practice review is open).
• CFPB UDAAP unfair-conduct triggered.
• ECOA discrimination-on-protected-basis triggered (protected class via self-employment-as-proxy-for-race-ethnicity).
• Fair Housing disparate-impact-housing-decision triggered.
• No adverse-action notice issued (human-in-loop controls caught all 12 AI-recommended declines that the underwriter ultimately upgraded).
• California DFPI state-reporting obligation met (filed 2026-11-15, within statutory 90-day window).
• Federal CFPB / DOJ / HUD referral declined for now — rationale documented; re-evaluation if VendorR's v5.3 remediation doesn't close the gap by 2027-Q1.

Composes with

Repo	Role
ai-incident-card-spec	The base spec this profile extends
mls-data-access-vault-contract-profile	Sibling PropTech profile — pairs the Decision Card vault contract with RESPA + ECOA + Fair Housing + MLS + GLBA categories
mortgage-decision-record-audit-stream	Sibling PropTech repo — the audit-stream ledger of which AI tool read which mortgage application field
respa-readiness-evidence-bundle	Sibling PropTech profile — assembles the broader RESPA + ECOA + Fair Housing evidence bundle
medical-adverse-event-incident-card	Sibling HealthTech profile — same Incident Card spec, FDA MedWatch + EU MDR + IMDRF instead of CFPB + ECOA + Fair Housing + ALTA
ai-student-record-incident-card-profile	Sibling EdTech profile — same Incident Card spec, FERPA + COPPA + IDEA + Title VI taxonomies
state-real-estate-ai-disclosure-tracker	Sibling PropTech repo — the state-reporting deadlines populated in state_reporting_obligations[] come from this tracker

Compliance posture

PropTech-readiness scaffolding for AI-system incident reporting in residential real estate + mortgage finance + title insurance contexts. The profile and its examples support a lender / broker / title-company's program toward CFPB UDAAP enforcement readiness, ECOA Reg B enforcement readiness (12 CFR Part 1002), Fair Housing Act enforcement readiness (42 USC §3601 + 24 CFR Part 100), RESPA Section 8 enforcement readiness (12 USC §2607), ALTA Best Practices alignment, HUD complaint-response readiness, DOJ fair-lending referral readiness, and 50+ state real-estate / mortgage / title-insurance regulator notification readiness — does not by itself establish compliance with any of them. Per the standing public-language guardrail: readiness · evidence · posture · controls · scaffolding — never "fair-lending-compliant" or "RESPA-cleared" without an external attestation.

License

MIT — see LICENSE. Spec/profile repos in the Suite are MIT-licensed so adopters can implement freely; reference implementations are AGPL-3.0.