Compliance

Where FirstLook stops and the lender starts

FirstLook is a comparison tool for the dealership. It is not a lender, not a credit bureau, and not a party to the credit decision.

What FirstLook is

Software that compares a customer’s deal to the written program rules your lenders have already sent you, then tells you which lenders the deal fits. It is the same comparison a careful F&I manager does by hand with fifteen PDFs open.

What it is not

It does not pull credit. The bureau is pulled by the dealership through its existing provider and uploaded. It does not submit applications. It does not approve, decline, counter or set a rate. Every one of those remains with the lender, and with the person at the dealership who chooses where to submit.

Fair lending

The prohibited bases under the Equal Credit Opportunity Act are not inputs. Race, color, religion, national origin, sex, marital status, age (other than capacity to contract) and receipt of public assistance are not read from the bureau or the application, are not stored, and cannot affect a ranking.

Rankings are produced by fixed rules taken from the rate sheets, not by a model that learns from past decisions. The same deal against the same sheets always ranks the same way, and the rules it used can be printed.

Adverse action

Because FirstLook does not decline anyone, it does not generate adverse action notices. Those remain the lender’s obligation, and the dealership’s own obligations are unchanged by using FirstLook. [Your compliance counsel should confirm how FirstLook fits your existing adverse action process.]

Data

Bureau files and deal data stay in your dealership’s account. They are not shared across dealerships and are not used to build a shared database. FirstLook uses a large language model (Anthropic’s Claude) to read PDFs and bureaus into structured fields. The ranking itself is ordinary code with no learning in it. [Retention periods, hosting region and the data processing agreement will be published before launch.]

A record of why

Every ranking is stored with the rate sheet versions and the inputs that produced it. If a customer, a lender or an examiner asks why a deal went where it did, you can show the sheet, the line and the number.

This page describes how the product is designed to work. It is not legal advice. [Review by counsel: pending.]

Send us your compliance questions

Email Cory@thewebalchemist.co.uk with anything your compliance officer or counsel wants answered, and we will reply in writing.