The four-fifths rule is a fifty-year-old screening heuristic that AI decisioning has made load-bearing again. It is a tripwire, not a verdict — and both halves of that sentence matter. What the Adverse Impact Ratio measures, where practical and statistical significance diverge, and why the computation should never come from the model being tested.
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A chatbot produces one reasoning event per interaction. An agent produces one per step — planning, tool selection, interpretation, revision — hundreds per task, invisible in the tool logs everyone mistakes for observability. The agent wave is a multiplication of exactly the thing enterprises never learned to govern.
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Buried in the April guidance is the sentence almost nobody is writing about: generative and agentic AI models are out of scope. That is not an exemption. It leaves bank LLM deployments with no tailored framework, full supervisory exposure, and a question every examiner can still ask: show me how this system reached this decision.
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The Digital Omnibus on AI cleared its final vote: the high-risk obligations that were due August 2 now arrive December 2, 2027. The content of the obligations survives; the deadline moved for standards readiness. The verified facts, what changed and what didn’t, and the implication that actually matters: the runway got longer, and undocumented decisions still don’t backfill.
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The fastest way to run a big model turns out to be letting something small do most of the talking. Speculative decoding drafts tokens cheaply and verifies them in parallel — provably without changing the output. DeepSeek-V3 builds the drafter into the model itself and gets ~1.8× decoding speed. The pattern — cheap generation under strict verification — is one we recognize. The guarantee that makes it free at the token level is exactly what verification loses one level up, and that difference is worth understanding precisely.
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Colorado repealed its landmark AI Act before it ever took effect and replaced it with something narrower: SB 26-189, built around automated decision-making technology, disclosure, and a consumer right to meaningful human review, effective January 1, 2027. The mandate list shrank. The question that survives — review of what, exactly? — is the one worth preparing for.
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