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Compliance & legal

Affected-person notices

Compliance & legalPortal users10 min read

An adverse outcome is one that went against the subject: a claim denied, a loan declined, a refund refused, an account closed. Several regimes require the person to be told, in plain language, what was decided, what role an automated system played, the main factors, what information was used, and how to ask for a human review. Stratl turns that duty into a workflow where every step is a signed record.

Framework Notice due Notes
Colorado ADMT 30 days after the decision Right to reconsideration by a reviewer with authority to override
ECOA / Regulation B 30 days after the decision Specific principal reasons; the statutory non-discrimination statement is included verbatim
EU AI Act, Article 86 No fixed clock in the pack Right to an explanation of the AI system’s role and the main elements of the decision

Every adverse decision appears in the notice queue (Reports page) with its deadline and days left, until a notice for it is sent.

  1. Draft. From the decision page, choose a framework and press Draft notice. Stratl writes the notice from the record. If an Anthropic API key is configured, Claude drafts it in plain language; either way, every sentence must cite the record field it came from, and a draft that cites anything not in the record is discarded for the built-in template. The rights text is legal wording and is never paraphrased. The draft is marked DRAFT and can be edited until it is approved.

  2. Approve. A named person, with an authority such as compliance_lead, approves it. The content locks. A signed workflow record DEC-WF-… (action notice.approve) is written, linked to the decision.

  3. Send. Choose how. Email, sent by Stratl delivers the approved notice through Stratl’s email provider to the person’s address and keeps the provider’s message id on the notice. Post, your portal or other record that you sent it elsewhere. Either way a signed record (action notice.send) is written, carrying the delivery facts. The person’s email address is kept on the notice; only its fingerprint enters the record.

  4. Withdraw, at any stage, with a reason and a name: sent to the wrong person, the decision was reconsidered, the draft was wrong. A sent notice stays sent in the record; the withdrawal is a further signed record (action notice.withdraw).

The notice has a fixed structure, in the language of the framework:

  • What was decided, one to three plain sentences.
  • The role of the automated system: what the software did and what people did.
  • The main factors the decision rested on, each traceable to a record field.
  • Information that was used, by category, and how to request it.
  • Your rights under the named framework, verbatim.
  • Human review: whether it is available and how to request it.
  • A reference (the decision id) so the person’s reply can be matched to the record.

In the portal, Read the draft opens it as a page; the emailed copy is the same content without the field citations.

When the person asks for a human review, record it from the decision page: who requested it, who reviewed it and with what authority, what evidence they considered, the outcome (upheld, modified, overturned) and the rationale. It becomes its own signed record, DEC-RC-…, linked to the original; the rationale is fingerprinted, never stored in the index. Records whose outcome was overturned are not adverse.

Drafting, approving, sending, withdrawing and recording a reconsideration need the notices:manage permission: owners and admins. Engineers and auditors can read every notice. Every action asks for the acting person’s name, which is written into the workflow record.

POST /v1/decisions/{id}/notices drafts, PATCH /v1/notices/{id} edits a draft, POST …/approve, POST …/send (with channel, sent_by and, for email, to), POST …/withdraw (with reason and withdrawn_by), GET /v1/notices/queue lists what is owed. API reference.