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Upstart AI failures

Every documented AI failure involving Upstart on the AI Failure Index, classified by the mechanism that broke.

Failures
3
Highest severity
High
Span
2022 to 2026
Failure modes
2
By severity
FI-0297Fintech & PaymentsHigh
Hallucination

Upstart Model 22 miscalibration and CFPB terminates no-action letter

Upstart disclosed calibration problems with its Model 22 in April 2026, triggering investor scrutiny and legal activity, while the CFPB had terminated its no-action letter for Upstart in 2022, forming the basis for heightened regulatory exposure.

Confidence
High (multi-source, primary)
Upstart Holdings, Inc.3 sourcesPrimaryPublicApr 2026
FI-0088Fintech & PaymentsHigh
Policy Violation

Upstart rejected its fair-lending monitor's less-discriminatory model, ending the monitorship

An independent fair lending monitor (Relman Colfax) found statistically significant approval disparities for Black applicants in Upstart's AI lending model during a multi-year oversight process from December 2020 through March 2024. The monitor proposed a less discriminatory alternative (LDA) model to address these disparities, but Upstart rejected it on accuracy grounds and offered its own alternative, which the monitor declined to validate. The disagreement ended the monitorship in an impasse, leaving the approval disparities unremediated.

Confidence
High (multi-source, primary)
Upstart3 sourcesPrimaryPublicMar 2024
FI-0337Fintech & PaymentsHigh
Policy Violation

Upstart credit models challenged for disparate impact on minority borrowers

The CFPB revoked a regulatory exemption for Upstart in June 2022 after its AI credit models were challenged for disparate impact on minority borrowers. The controversy centered on the use of educational data in the automated underwriting system.

Confidence
High (multi-source, primary)
Upstart2 sourcesPrimaryPublicJun 2022

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