Could Large Language Models work as Post-hoc Explainability Tools in Credit Risk Models?

Credit decisioning is a high-stakes task in which model outputs must be accurate and explainable to support compliant decisions. Although modern credit risk models such as eXtreme Gradient Boosting (XGBoost) and Graph Neural Networks (GNNs) improve predictive performance, their explanations are often too technical for stakeholders creating communication gaps that can shape approvals, denials, and fairness judgments. We examine whether Large Language Models (LLMs) can serve as explanation layers that translate post-hoc explanation artefacts into stakeholder-appropriate risk narratives. Using Freddie Mac single-family loan-level data, we develop three pipelines: standard tabular (XGBoost + SHAP), and two with alternative data, a pure network-based (GNN + GNNExplainer), and a bimodal one (combining tabular and network data). We generate narratives with three LLM configurations: a small fine-tuned LLM (Gemma 3 4B), a large fine-tuned LLM (DeepSeek R1 70B), and a zero-shot commercial LLM (Gemini 2.5). Explanation quality is evaluated through automated checks across all pipelines and a human study of bimodal explanations comparing credit risk professionals and non-professionals on eight decision-relevant dimensions. We have three main findings. First, the pipeline accounts for higher variance in evidence-grounding scores than the language model, meaning that the binding constraint on explanation quality is the evidence representation, not the model used. Second, the explanation narratives reliably name the influential factors but are less reliable when stating the direction of influence, which may be consequential for adverse-action communication. Finally, professionals apply stricter evidentiary standards than non-professionals. We discuss implications for the governance of risk models, including deployment considerations and the value of domain-aligned LLMs in regulated credit settings.

Credit scoring increasingly relies on models whose decision logic cannot be read off their parameters, in tension with supervisory expectations that adverse decisions be explainable. A common proposal closes that gap with a language model: compute feature attributions, hand them to an LLM, and let it write the rationale. We build such a system end to end and test whether the second half of the promise holds. The predictive component is a multi-scale stacking ensemble fusing four differently regularised gradient-boosting learners with a residual network through a neural meta-learner trained on out-of-fold predictions. On a public 32,581-application credit dataset it reaches test ROC-AUC 0.9539 (95% CI [0.9462, 0.9616]) and PR-AUC 0.9137, beating the best single model by Delta-AUC = 0.0143 (p = 0.016 under a conservative independence assumption). Our central finding is asymmetric. The ranking gain is real but operationally small: at the F1-optimal threshold the ensemble avoids only six additional missed defaults out of 1,422 against a tuned random forest, cutting cost-weighted loss by under 2%. The narrative layer fails in a way prompt engineering alone does not fix. In an audited case the model named three factors as risk-increasing that the supplied attributions scored as risk-reducing, omitted the dominant driver, and introduced a feature never given to it. We trace this to properties we measure rather than assume: SHAP and LIME agree on which features matter (overlap@10 = 0.80) but not on their order (tau = 0.43, p = 0.18), and the attribution sign for the model's most sensitive input is near a coin flip across applicants (modal-sign share 0.53). Calibration (ECS = 0.117) and perturbation stability (DPD = 0.078) both fall short of our own thresholds. Constrained prompting is necessary but not sufficient: grounding must be verified after generation, not assumed.

Large language models (LLMs) achieve strong performance and have revolutionized NLP, but their lack of explainability keeps them treated as black boxes, limiting their use in domains that demand transparency and trust. A promising direction to address this issue is post-hoc text-based explanations, which aim to explain model decisions in natural language. Prior work has focused on generating convincing rationales that appear to be subjectively faithful, but it remains unclear whether these explanations are epistemically faithful, whether they reflect the internal evidence the model actually relied on for its decision. In this paper, we first assess the epistemic faithfulness of LLM-generated explanations via counterfactuals and show that they are often unfaithful. We then introduce a training-free method that enhances faithfulness by guiding explanation generation through attention-level interventions, informed by token-level heatmaps extracted via a faithful attribution method. This method significantly improves epistemic faithfulness across multiple models, benchmarks, and prompts.