When Can First-Order Models of Fine-Tuning Bound Forgetting?

Fine-tuning a language model on new data can make it forget facts that it should keep. We ask whether measurements taken at the start of a fine-tuning run can bound, for each protected fact, the probability that the run makes the model forget it. In LoRA fine-tuning with stochastic gradient descent on models from 0.6B to 14B parameters, a first-order response model estimated by finite-difference probes predicts changes of per-fact margins with correlation 0.974-0.998. Predictions of forgetting built on this model nevertheless failed, because forgetting requires parameter changes far outside the region in which the model was validated. The probes can, however, bound the probability that a margin first falls below a boundary near zero: we derive Freedman and Azuma first-passage bounds for a linear surrogate of the margin and test on new runs whether they hold for the model. The bounds contain a term R that measures how much the response coefficients change during the run. The simplified Freedman bound, which sets R = 0, certified most facts but was violated in 14 of 112 conditions, and every fact on which it was violated had R >= a, where a is the distance of the fact's margin to the boundary. The complete Freedman bound certifies only facts with R = a. We found this pattern post hoc and tested it in two preregistered confirmatory studies with 43 new conditions: the complete bound held in all of them, and the simplified bound failed there on only 3 facts, each with R >= a. First-order models of fine-tuning can thus bound forgetting on the facts whose response coefficients change by less than their distance to the boundary.