medium · Frm Part 2 Current Issues

A risk function is validating a complex Gradient Boosted Machine (GBM) model used for retail credit scoring. The developers have provided SHAP (Shapley Additive Explanations) values to meet regulatory adverse-action notice requirements.

Which of the following statements best describes a structural risk-management limitation of using post-hoc SHAP attributions compared to using an inherently interpretable model?

  1. SHAP values are global importance metrics and cannot provide the case-by-case 'reason codes' required by fair-lending regulations.
  2. The use of SHAP values inherently violates the monotonicity constraints required for conceptual soundness in credit scoring.
  3. SHAP values cannot handle non-linear feature interactions, making them less accurate than the GBM's internal importance metrics.
  4. SHAP attributions are approximations of the model's behavior and may exhibit instability across different feature resamples.

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