What does Colorado AG proposed ADMT rules say about AI in banking?

What are the key points of Colorado AG proposed ADMT rules?

• Filed with the Colorado Secretary of State on August 11, 2026 as an expedited rulemaking to meet the January 1, 2027 statutory deadline
• Creates 'midstream developers' — firms that integrate covered ADMT into their own products — who must obtain upstream documentation and pass it downstream
• Two alternative 'materially influences' tests: whether the decision-maker reached an independent judgment after reviewing the output, or whether other information played a substantially larger role than the ADMT output; the AG notes the second is easier to satisfy
• Adverse-outcome disclosures must state the decision, the deployer's purpose, human reviewer roles, effective dates, the principal reasons with specificity, and whether inferences or risk scores drove the outcome — generic references to internal policy are insufficient, and disclosures must be tailored to the sector (e.g. lending)
• Meaningful human review: reviewers independent from the original decision-maker where feasible, trained, insulated from managerial pressure, empowered to override, and barred from using ADMT to conduct the review; 'commercially reasonable' scales with harm severity and deployer capacity
• Also implements HB 26-1263 disclosure, age-estimation, and reporting duties for conversational AI operators
• Deadlines: September 4, 2026 (comments for revised draft), September 23, 2026 (revised draft target), October 26, 2026 (hearing in Denver/videoconference and final written comments)

What did Colorado AG proposed ADMT rules change for banks?

This is where the ADMT Act's bank-relevant detail is being decided. The 'materially influences' test determines whether a scorecard that feeds an underwriter's judgment is covered at all; the disclosure rules go beyond the reason-code conventions of Reg B adverse action notices; and the human-review standard would require most lenders to formalize an appeal channel staffed independently of the original credit decision. Banks with Colorado customers have until October 26, 2026 to comment.