TransUnion SmartMove is the most widely used tenant screening service among individual landlords and small property managers in Colorado. Its AI-generated tenant risk scores influence housing decisions for thousands of Colorado renters every month. And under the Colorado AI Act, every Colorado landlord using SmartMove to make tenancy decisions has formal compliance obligations that take effect June 30, 2026.
How SmartMove Uses AI
TransUnion's SmartMove platform is built around AI-assisted risk assessment. The platform uses machine learning to generate ResidentScore — a risk scoring system that evaluates tenant applications and produces a recommendation about the applicant's rental risk level.
ResidentScore draws on credit history, rental payment history, eviction records, and other data points. The AI synthesizes these inputs into a score that landlords use to make acceptance or rejection decisions. When that AI score influences whether a Colorado resident gets housing, it is a consequential decision under the Colorado AI Act.
SmartMove also uses AI in the way it processes and presents criminal background information, flags potentially adverse findings, and generates the overall applicant recommendation that landlords see at the end of the screening report.
Why Housing Decisions Carry the Highest Stakes
The Colorado AI Act explicitly lists housing as a consequential decision category. This is not accidental. Housing access is a fundamental need, and AI-assisted decisions about who gets housing carry real civil rights implications — particularly where credit scoring and criminal history screening intersect with protected class status.
Colorado has also enacted significant source-of-income protection laws and has an active Fair Housing enforcement environment. Colorado landlords using SmartMove face a compliance stack that includes the Colorado AI Act, the Colorado Anti-Discrimination Act, federal Fair Housing Act, and Colorado's source-of-income protections. AI tenant screening is at the intersection of all of these.
The Appeal Process Requirement
This is the obligation that catches most Colorado landlords off guard. The Colorado AI Act requires that when you use an AI system to make a consequential decision about a Colorado resident, you must give that person a meaningful opportunity to appeal the decision and request human review.
For rental decisions, this means: when you decline an applicant based partly on a SmartMove screening result, you must have a process that allows that applicant to contest the decision, request that a human review it, and receive a substantive response. You must communicate this process to the applicant at the time of the adverse decision.
Building this process does not require a law firm. A simple written policy, a named contact, and a defined response timeline satisfies the requirement. But it needs to exist before June 30th.
What Colorado Landlords Using SmartMove Must Do
Send a formal Colorado AI Act documentation request to TransUnion's legal department, specifically referencing SmartMove and its AI-assisted tenant risk scoring. Complete an impact assessment for SmartMove's use in your screening process. Update your rental application materials to disclose that AI-assisted screening is used. Create a written appeal process. Document all of this in a compliance file before June 30th.
This article is for informational purposes and does not constitute legal advice. For legal advice specific to your situation, consult a licensed Colorado attorney.