AI Policy for Mortgage Brokers: What It Must Cover

Last reviewed: October 27, 2026. General information, not legal advice. Facts about Fannie Mae and Freddie Mac are linked to their official sources below.

Why a mortgage broker needs an AI policy now

Your loan officers probably already use AI: to write emails, summarize documents, draft social posts or take call notes. Many LOS, CRM and marketing tools now have AI features built in. Each of those can touch borrower data.

Two investor rules now spell out AI governance duties. Freddie Mac Guide Section 1302.8 conditions a Seller/Servicer's use of AI/ML on written policies approved by senior management, communicated to staff, owned and reviewed at least annually. Fannie Mae Supplement Section 4 requires a formal governance program for what it now calls Super Intelligence (SI), including an inventory of use cases.

These rules are written for the companies that sell loans to or service loans for Fannie Mae and Freddie Mac. Most brokers are not those companies. But the wholesale lenders you work with are, and Fannie Mae's Supplement says a Company "shall cause its third parties involved with Company's activities under the applicable Underlying Agreements to comply with the Supplement". A short, signed AI policy is the easiest way to answer when a lender asks.

What an AI policy for mortgage brokers should include

Scope and definitions. Who it covers, what counts as an AI tool, and what borrower data means.
Approved tools list. Which tools staff may use, for what, and whether borrower data is allowed in each.
Allowed, approval needed and prohibited uses. Clear lines, especially for borrower data and anything that reaches a borrower.
Human review. A person checks AI output before it goes into a loan file or out the door.
Confidential output. Fannie Mae's Section 4 says "SI outputs derived from Confidential Information should be treated as Confidential Information." Your policy should say the same.
Senior approval. Freddie Mac 1302.8 requires approval by senior management "(or the equivalents thereof)". Record the name and date.
Named owner and annual review. Both GSEs call for an owner who reviews the policies at least annually.
Vendor oversight. Ask how each vendor's AI uses your data. Freddie Mac says its Seller/Servicers need a third-party risk program that covers vendor AI; Fannie Mae requires third party SI governance that is "no less protective".
AI use inventory. A list of each AI use, its purpose and its safeguards. Section 4 requires one.
Incidents. How staff report a problem, such as borrower data pasted into an unapproved tool.
Training and acknowledgment. Every user signs before using AI and again each year.
Disclosure summary. Both GSEs can ask their counterparties for the types of AI used, the purpose and manner of use, and safeguards. Keep a one-page summary ready.

Acceptable use policy or full governance policy?

An acceptable use policy is the staff-facing rule sheet: what you may and may not do with AI. It is where most brokers should start. Our free mortgage AI acceptable use policy template covers it.

A governance policy adds the program around it: risk tiers, the approval memo, the inventory, vendor reviews, incident response and the annual review calendar. That is closer to what the GSE rules describe for their Seller/Servicers.

Five mistakes to avoid

Copying a generic template that never mentions borrower data.
Writing a policy nobody signs. Without acknowledgments, you cannot show staff received it.
Forgetting AI features inside tools you already pay for.
No owner and no review date, so the policy goes stale.
Claiming the policy makes you "approved" by anyone. Fannie Mae and Freddie Mac do not certify broker AI policies.

How to get it done this week

Copy the free template and fill in the brackets.
Check your gaps with the 15-point AI policy checklist.
Send the vendor AI questions to your LOS, CRM and marketing vendors.
Have your senior leader sign, then collect staff sign-offs. The BrokerLumen portal tracks them free for up to 10 staff.

Skip the blank page

The $99 AI Policy Starter gives you an editable AI acceptable use policy, a 15-point readiness checklist, a staff acknowledgment form and an approved AI tools list. Use it with the Free portal plan to track staff sign-offs for up to 10 staff. Every BrokerLumen kit is priced under $1,000. The AI Policy Starter includes a staff acknowledgment form; the AI Policy Kit (3 months) and AI Team Kit (a full year) include Small Shop portal access with staff sign-off tracking built in.

Get the AI Policy Starter, $99 AI Policy Kit, $349 Compare kits

Frequently asked questions

Do mortgage brokers need an AI policy?

Freddie Mac Section 1302.8 and Fannie Mae Supplement Section 4 apply to the companies that sell loans to or service loans for them, and to Companies subject to the Supplement. Brokers are not named, but wholesale lenders may ask brokers about AI use, and a signed policy is the simplest answer.

What should an AI policy for a mortgage broker include?

Scope, an approved tools list, allowed and prohibited uses, human review, rules for borrower data and AI output, senior approval, a named owner with annual review, vendor oversight, an AI use inventory, incident reporting, training with acknowledgments and a disclosure summary.

Is there a free AI policy template for mortgage brokers?

Yes. BrokerLumen publishes a free mortgage AI acceptable use policy template you can copy without giving an email address.

Does an AI policy guarantee my company meets Fannie Mae and Freddie Mac requirements?

No document can guarantee that. A policy aligned to Freddie Mac 1302.8 and Fannie Mae Section 4 is a starting point. Have counsel confirm your obligations.