# Text to Trust: Evaluating Fine-Tuning and LoRA Trade-offs in Language Models for Unfair Terms of Service Detection

arXiv: https://arxiv.org/abs/2510.22531 · HTML: https://mlsanity.com/paper/2510.22531/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 5 of its 11 references that are in the map.
- First posted on arXiv 26 Oct 2025.

## Builds on (most cited first, 5 of 5)

- [BERT: Pre-training of Deep Bidirectional Transformers for Language Understanding](https://mlsanity.com/paper/1810.04805/) (2018)
- [QLoRA: Efficient Finetuning of Quantized LLMs](https://mlsanity.com/paper/2305.14314/) (2023)
- [SaulLM-7B: A pioneering Large Language Model for Law](https://mlsanity.com/paper/2403.03883/) (2024)
- [CLAUDETTE: an Automated Detector of Potentially Unfair Clauses in Online Terms of Service](https://mlsanity.com/paper/1805.01217/) (2018)
- [Unfair TOS: An Automated Approach using Customized BERT](https://mlsanity.com/paper/2401.11207/) (2024)

## Abstract (arXiv)

Large Language Models (LLMs) have transformed text understanding, yet their adaptation to specialized legal domains remains constrained by the cost of full fine-tuning. This study provides a systematic evaluation of fine tuning, parameter efficient adaptation (LoRA, QLoRA), and zero-shot prompting strategies for unfair clause detection in Terms of Service (ToS) documents, a key application in legal NLP. We finetune BERT and DistilBERT, apply 4-bit Low-Rank Adaptation (LoRA) to models such as TinyLlama, LLaMA 3B/7B, and SaulLM, and evaluate GPT-4o and O-versions in zero-shot settings. Experiments on the CLAUDETTE-ToS benchmark and the Multilingual Scraper Corpus show that full fine-tuning achieves the strongest precision recall balance, while LoRA-based models provide competitive recall with up to 3x lower memory cost. These findings highlight practical design trade-offs for efficient and domain-adapted LLMs, contributing open baselines for fine-tuning research in legal text processing.