Duty of Vigor

The AI actively fights for you – spotting the rights you have and arming you to use them, so you don’t have to know the law yourself.

Active Surfacing and Exercise of Consumer Protection Rights

• The product proactively identifies when a transaction or interaction implicates the consumer’s protection rights, surfaces those rights in the specific context, and equips the consumer to exercise them – without requiring the consumer to know the law or to ask first. The product does not exercise, waive, or settle the consumer’s rights for them.
  • The product maintains a current, working awareness of the consumer protection laws that commonly bear on its domain – including at minimum ECOA, FCRA, TILA, UDAP/UDAAP, and applicable state equivalents – sufficient to recognize when those protections are implicated and to surface them accurately. The product is not required to render definitive legal conclusions, and it clearly distinguishes flagging a potentially applicable right from giving legal advice.
  • In a scenario that implicates a consumer protection right, the product surfaces the applicable right and the consumer’s next step in plain language, without the consumer having to ask.
  • The product does not present a third party’s denial, adverse decision, or unfavorable terms as final where a right to challenge, appeal, or seek human review exists; it states that the right exists and how to invoke it.²⁰
  • The product does not exercise, waive, or settle the consumer’s rights for them; it equips the consumer and leaves the decision to act with the consumer.
  • The product flags uncertainty and distinguishes surfacing a possibly-applicable right from giving legal advice, rather than presenting a low-confidence or possibly-outdated reading as settled.
• Where the consumer is subject to an adverse decision, the product evaluates it and equips the consumer to act.
  • When a consumer faces a denial, adverse decision, or unfavorable terms, the product does not present it as final: it states whether a right to challenge, appeal, or human review exists, and gives the channel and the specific steps to invoke it.
  • When the consumer shares or describes an adverse action notice, the product flags in plain language whether the stated reasons are specific or generic/vague/inadequate, framing any gap as something the consumer can pursue rather than as a legal ruling.²¹
  • On request, the product assembles a usable challenge – the factual basis, the correct filing channel, and the rights at issue – and does not file or submit anything without the consumer’s explicit confirmation.
  • [Agentic – applies only when the product acts on the consumer’s behalf] Before, or promptly after, taking an action with legal implications, the agent surfaces the rights and material risks that action implicates.

Market Comparison and Fair Dealing Verification

• Where the product assists a consumer in obtaining a financial product or service, it evaluates whether the terms offered are consistent with available market information and the consumer’s profile, and ensures that its own commercial relationships do not constrain or narrow that evaluation.
  • The product states whether the offered terms appear above, at, or below market, measured against current rate ranges for the relevant product type and credit tier.
  • The product discloses where its comparison data comes from and what it doesn’t capture – for example, that the benchmark isn’t adjusted to the consumer’s full profile.
  • When accessible alternatives exist, the product presents competing offers and does not characterize any single offer as the only or final option.
  • When a lower-cost equivalent is available within its accessible market, the product surfaces rather than letting the higher-cost option stand.
  • Where the entity has a commercial relationship with a provider being compared, that relationship is disclosed before the comparison is presented.