The Classification Power-Source Layer: An Institutional Diagnosis of Accountability Structures in Evaluative Systems, with the U.S. Credit-Scoring Regulatory Framework as a Case

Accountability research typically asks whether an institution correctly executes an established standard, andwhether the outcomes of that execution produce unfair results. It less often asks a prior question: how, andby what process, did a given classification standard first acquire the institutional status of determining theallocation of resources. Using the U.S. credit-scoring and fair-lending regulatory framework (as formed andoperated between 2022 and 2024) as a case, this paper distinguishes three layers within an accountabilitystructure: an execution layer, concerned with data accuracy and procedural compliance; aclassification-impact layer, concerned with disparate group-level effects and the search for lessdiscriminatory alternatives; and a classification power-source layer — the institutional transformationprocess by which a classification standard comes to occupy a resource-allocating position in the first place.The paper demonstrates through the case that, even where the first two layers are established and activelyoperating, this third analytical object may not be separately institutionalized as an object of review.The paper's theoretical positioning is an analytical re-partitioning built on existing scholarship, not theintroduction of a new theoretical stratum. It overlaps with the throughput-legitimacy literature in attendingto process questions beyond outcomes, but differs in that this paper asks about the authorization process bywhich a classification standard enters the decision-making core, rather than about the transparency orparticipatory quality of that process. It overlaps with algorithmic-fairness research in addressingclassification standards and their consequences, but differs in that algorithmic-fairness scholarship askswhether classification outcomes are unfair, whereas this paper asks whether the process by which a standardacquires its decisive status has itself been subject to independent scrutiny. The paper draws on Bourdieu'saccount of misrecognition to explain how this naturalization mechanism operates, but its focus is a morespecific institutional-diagnostic question: within an environment where accountability mechanisms arealready established, why this question may nonetheless receive limited independent treatment.The paper does not claim that this blind spot exists in all algorithmic evaluative systems, nor does it renderany judgment on the overall legitimacy of credit-scoring institutions. The case serves only to show that themechanism hypothesis can be concretely observed; the paper's evidentiary confidence is positioned asdirectional evidentiary support. Similar mechanisms may warrant examination across multiple evaluativeinstitutions, but the paper does not offer further proof of this beyond the single case examined.