Model-risk notes for informal-worker digital credit

This fictional Bangladesh case tracks a digital-credit score that inferred repayment from call-detail patterns. Borrowers in irregular work were more often declined after festival weeks, when call volume dropped for reasons unrelated to risk.

Padma Inclusive Finance Institute drafted one-page model-risk notes for consumer groups and a regulator sandbox. The notes list prohibited proxies, a required human appeal path, and a six-month sunset unless a fairness audit is repeated.

The Observatory includes the case as an example of accountability artefacts that travel between researchers and supervisors without exposing raw customer data.