Obtain the supplier’s substantiation records: Before approval | AIGP
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Obtain the supplier’s substantiation records: Before approval under US consumer-protection and competition

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Easy

Supplier substantiation records directly test the advertised accuracy; outsourcing, contracts, and disclaimers do not eliminate responsibility.

The question

A bank is considering a supplier’s AI that extracts financial-document fields. The supplier advertises 98% accuracy, but the bank has not independently tested it. Before approval under US consumer-protection and competition rules, which evidence should resolve the supplier-reliance uncertainty?

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  1. Ask an independent consultant to review the workflow generally.
    A general workflow review may identify process issues, but it does not specifically substantiate the advertised extraction accuracy.
  2. Rely on the contract’s indemnity and audit rights.
    Contractual protections allocate some risk but do not establish that the supplier’s public accuracy claim is truthful or supported.
  3. Obtain the supplier’s substantiation records. ✓
    Supplier testing and substantiation records directly address whether the advertised accuracy claim has supporting evidence before the bank relies on it.
  4. Approve after adding a disclaimer that identifies the external provider.
    Naming the supplier and adding a disclaimer does not remove ordinary responsibility for unsupported accuracy representations.
The trap
When a vendor supplies the claim, seek claim-specific testing evidence rather than relying on contractual allocation or disclaimers.

How to remember it

Supplier substantiation records directly test the advertised accuracy; outsourcing, contracts, and disclaimers do not eliminate responsibility.

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