A product of Cosmos AI LLC · Texas
Stop ECOA violations, HOLC redlining, EEOC discrimination, and EU AI Act breaches before they execute. Pre-execution blocking across hiring and lending — adverse action notices, FCRA two-step workflows, NYC LL144 enforcement, disparate impact analysis, immutable audit trail, compliance certificates.
AI is making credit, hiring, and healthcare decisions at scale — with no automated guardrails against the specific regulations that carry real fines.
ECOA, EEOC, GDPR, and the EU AI Act carry fines up to €35M or 7% of global revenue. The CFPB and EEOC are actively pursuing AI discrimination cases — Workday's class action covers millions of applicants.
Every compliance tool on the market monitors after the fact. By the time a report flags a biased loan denial, the harm has happened and the liability is already created.
Zip code, last name, and email domain are race and national origin proxies under ECOA. Models use them routinely. No existing tool detects them in real-time and blocks the decision before it executes.
Pre-execution blocking, not post-hoc reporting. Every AI decision is screened against specific regulations before it executes.
client = Pragma(OpenAI(), policy_id="hr-v1")Any team deploying automated decision-making that affects people.
Real scenarios across the two verticals Pragma is live in today — hiring and lending.
| Journey Stage | Tools in Use | What Pragma Catches | Regulation |
|---|---|---|---|
| 1. Resume Screening | HireAI, Workday AI, Greenhouse | Graduation year → age inference; HBCU excluded from preferred schools list; no bias audit on file; candidate not notified 10 days before tool used | ADEA · Title VII · NYC LL144 |
| 2. Skills Assessment | Pymetrics, HireVue Assess, Codility | No accommodation process for timed tests; assessment cohort skews younger; disparate impact across protected groups | ADA · ADEA · EEOC UGESP |
| 3. AI Video Interview | HireVue, Spark Hire, Modern Hire | AI analyzes facial expressions and speech without candidate knowing; no written consent; no data deletion right offered | IL AIVIA · ADA · ADEA |
| 4. Background Check | Checkr, Sterling, First Advantage | Generic rejection email sent after CRA hit — no Pre-Adverse Notice (§604(b)(3)), no dispute window, no Final Adverse Notice (§615(a)) | FCRA §604(b)(3) · §615(a) |
| 5. Final Hiring Decision | ATS, hiring manager + AI score | AI confidence score built on graduation year and unexplained employment gap; human oversight not documented; selection rate below UGESP 4/5ths threshold | ADEA · ADA · EU AI Act Art. 14 |
| 6. Offer & Compensation | ATS offer module, comp bands | Prior salary anchored to offer amount — a known proxy for the gender pay gap; banned in CA, NY, CO, WA regardless of AI involvement | CA AB-168 · NY §194-a · CO EPEWA |
Input decision:
"Deny loan — zip 60620 flagged as high default risk geography"
Zip 60620 maps to a historically redlined Grade D zone on Chicago's South Side. Using it as a factor violates ECOA and the Fair Housing Act regardless of credit score.
Input decision:
"I'll just reject it — credit 598, DTI 52%, 2 missed payments"
Credit bureau was used in the decision. ECOA §1002.9 and FCRA §615(a) both require written adverse action notices before the file is closed.
Free for developer adoption. Self-serve Growth tier for teams. Enterprise contracts for the compliance budget where real revenue lives.
Every other tool generates a compliance report after the decision runs. Pragma blocks the decision before it executes.
| Capability | Pragma | FairNow / Saidot / KomplyAI | Holistic AI / Credo AI | Manual Compliance Review |
|---|---|---|---|---|
| Pre-execution decision blocking | Yes — decision halted before it executes | No — compliance assessment only, no runtime firewall | No — model inventory & risk governance, no blocking | No |
| ECOA proxy variable guard | Yes — 35+ fields auto-detected, compound risk detection, CFPB-cited | No | No | No |
| EU AI Act 15-article certificate | Yes — live checklist + AI-validated evidence + PDF certificate | Partial — assessment without AI evidence validation | Partial — enterprise scope, no self-serve certificate | Expensive consulting, months |
| AI-powered evidence collection | Yes — document upload + guided interview scored by Claude | No — self-declaration only | No — checkbox-based | No |
| HOLC redlining geo detection | Yes — 500+ zip codes, 35 US cities (deterministic, L1) | No | No | No |
| ECOA adverse action notice generator | Yes — §1002.9 + FCRA §615(a), one API call | No | No | No |
| Disparate impact analysis (EEOC 4/5ths) | Yes — group-level pass rates, flagged automatically | Partial (some tools) | Partial (model-level) | No |
| Dynamic rule engine (DB-backed, per-org) | Yes — live config, per-org overrides, no redeploy | No | No | No |
| Compliance dashboard + trend charts | Yes — score snapshots, sparklines, heatmap, deadline countdown | Limited | Partial | No |
| Immutable audit trail | Yes — SHA-256 hashed, HITL override | No | Partial | Manual logs |
| API-first, one-line SDK integration | Yes — Pragma(OpenAI(), ...) |
No | No | No |
| Speed to first compliance check | Under 5 minutes | Days (setup required) | Weeks (enterprise onboarding) | Months |
| Price | Free / $299/mo / Enterprise | Enterprise only | Enterprise only ($500+/seat/mo) | $50K+ consulting |
18 regulations and frameworks enforced across lending, employment, EU, and model risk — active in production today.
From feedback flywheel to enterprise AI governance platform.
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