First Atlantic's unsecured-loan funnel was bleeding. Average time-to-decision was 12.3 days, application abandonment between submission and decision sat at 34%, and the bank had quietly tightened its policy cutoffs four times in two years to compensate for rising charge-offs in the 660-700 FICO band.
The existing underwriting stack was a brittle combination of a 2014-era logistic regression scorecard, a mainframe rules engine that only the original vendor could change, and 23 underwriters in Charlotte who manually reviewed every application above $35,000. Worse, the bank's last fair-lending review had flagged a statistically significant adverse-action disparity in two protected classes that nobody could fully explain.
The CEO's directive was sharp: get to same-day decisions on the bulk of the book, do it without raising loss rates, and produce a model risk dossier that the OCC examiners would consider exemplary -- not just adequate.
TekNinjas delivered an end-to-end MLOps platform on a hybrid GCP / on-prem footprint over an 11-month engagement. The work was scoped jointly with the bank's MRM (Model Risk Management) function from week one -- we wrote SR 11-7 documentation in parallel with code, not after.
We trained two complementary LightGBM models -- a probability-of-default model and an early-delinquency model -- on 7.2 years of internal performance data enriched with Plaid cash-flow signals, FactorTrust thin-file attributes, and (for borrower opt-in) verified income from Argyle. Feature stores ran on Vertex AI Feature Store with a 90-day rolling backfill. Hyperparameter search used Vertex AI Vizier with strict separation between train, validation, and out-of-time test windows.
Every model release passed a four-stage fairness gate: Disparate Impact Ratio under Equal Opportunity, Demographic Parity Difference, calibration drift across protected classes, and adversarial debiasing on the residual feature set. SHAP-based per-decision explanations were persisted to BigQuery and translated into Reg B-compliant adverse-action reason codes by a deterministic mapping layer that compliance signed off on.
The serving layer ran on Cloud Run with a 95ms p99 inference budget. Real-time feature lookups were cached in Memorystore with a 30-second TTL. Borderline cases (probability-of-default in a calibrated grey zone) routed to a streamlined underwriter queue that surfaced the model rationale, the top five SHAP features, and a recommended counter-offer. Every override -- underwriter or model -- was captured and fed back into a weekly governance scorecard reviewed by MRM and Compliance.
The platform went live in production in March 2026 after a 90-day champion-challenger period running silently behind the legacy scorecard.
decisions in under 90 seconds
lift in approval rate
OCC MRA findings
“We expected speed. What we did not expect was that the same platform would demonstrably improve our fair-lending posture. TekNinjas brought equal rigor to the model science and the regulatory framing -- our examiners noticed.”
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