ZIP-as-proxy = redlining pattern — AI screening in DOJ crosshairs
—HUD AI guidance enforcement wave
Regulatory exposure — commonly overlooked:
Adverse action notice requires what data AI used — receipt IS the notice infrastructure. · Local Law 144 requires annual bias audit — Velaru receipts are continuous audit, not annual snapshot.
TAM / Exposure
44M US renter households · algorithmic screening litigation
Insurance lines
Landlord liability · Fair housing E&O
Exhibit authority
New York AI Governance Pack — FCRA §615 + Fair Housing AI Screening Pack