Last reviewed: November 9, 2026. General information, not legal advice. This free tool runs only in your browser. Your list is kept in this browser on this device until you clear it, and nothing is sent to BrokerLumen. No email required.
Why you need an AI use inventory
You cannot govern AI you do not know about, and a lot of it now arrives inside software you already pay for. Both GSEs now expect you to know where it is.
"Require the maintenance of an inventory of SI use cases"Fannie Mae Information Security and Business Resiliency Supplement, Section 4
In plain English: Keep a written list of every way your company uses AI. In the Supplement, Fannie Mae uses the term Super Intelligence (SI) for AI.
"Manage risks and appropriate governance of third party use of SI that is no less protective of these requirements"Fannie Mae Supplement, Section 4
In plain English: AI inside your vendors' products counts. Your inventory should include it, not just the tools your staff open themselves.
Section 4 takes effect January 18, 2027. Freddie Mac's Section 1302.8, in effect since March 3, 2026, requires Seller/Servicers to disclose on request the types of AI/ML they use, the purpose and manner of use, and their safeguards. An inventory is how you answer that request, and the same list answers most of a wholesale lender's AI questionnaire. If you are following the Section 4 readiness plan, this is week 2.
Where AI hides in a mortgage shop
Walk through each system below with the person who uses it most. Ask the vendor which features use AI and which are on by default.
- Loan origination system (LOS). Document classification, data extraction, condition suggestions, AI search or summaries of the file.
- Point of sale and borrower portal. AI helpers that answer borrower questions, prefill applications or read uploaded documents.
- CRM and marketing automation. AI-written emails and texts, lead scoring, next-best-action suggestions and send-time optimization.
- Pricing and product engine. Any feature that recommends a product, scenario or price adjustment from borrower data.
- Email and office suite. Built-in AI assistants that read mail, summarize threads or draft replies, often switched on by the vendor.
- Meetings and notetakers. AI notetakers that join calls, record, transcribe and summarize. See AI notetakers and call recording.
- Phone, texting and voice. AI receptionists, voice agents and AI text follow-up. See AI voice and texting rules.
- Website and chat. Chat widgets that answer with AI. See AI chatbot disclosure rules.
- Document and income processing. Tools that read pay stubs, bank statements or tax returns and calculate income.
- Staff AI chat tools and browser extensions. Company AI chat accounts, personal accounts used for work, and AI browser extensions that can read every page.
Not everything automated is AI. Freddie Mac's FAQ on Section 1302.8 says a system that only automates a manual process, without analyzing data or making a decision, is not AI/ML for that section. When in doubt, list it and mark it "Not sure"; it is easier to remove a row than to explain a missing one.
Build your inventory
Add one row per AI feature, not per vendor: one CRM can have three AI features with different risks. Download the CSV when you are done and keep it with your AI policy.
Your inventory: 0 items
| Review priority | Tool | AI feature or use | Where | Borrower data | Talks to borrowers | Influences decisions | On by default | Owner | Status | Next review | Remove |
|---|
Nothing added yet. Add your first tool above, or add the three example rows to see how it works.
Review priority is a simple sort to decide what to look at first: High when a tool influences decisions, talks to borrowers, or touches financial data and might influence a decision (Yes or Not sure); Medium when it touches any borrower data or an answer is "Not sure"; Low otherwise. It is not a legal risk rating.
After the list: five next steps
- Close the "Not sure" answers. Send the AI vendor due diligence questions to each vendor on the list.
- Review the High rows first. Check data handling, human review and the six basics in the AI controls checklist.
- Turn off what you do not need. Mark it "Not allowed" and record who switched it off and when.
- Get it approved. Have senior management approve the inventory with your AI policy, with the date and version.
- Set the review date. Recheck at least once a year and whenever a vendor announces a new AI feature.
Keep the policy and the sign-offs next to your inventory
The free BrokerLumen portal plan lets you publish your approved AI tools and AI rules, have up to 10 staff acknowledge them and see who has not signed yet. Start free, then add a kit if you want the full governance policy, inventory template with a disclosure summary and vendor questionnaires.
Start freeCompare kitsFrequently asked questions
What is an AI use inventory?
A written list of every way your company uses AI: the tool, the AI feature, what data it touches, whether it talks to borrowers or influences credit decisions, who owns it, its approval status and when it is next reviewed. Fannie Mae's Supplement Section 4 requires the maintenance of an inventory of SI (AI) use cases.
Does a small mortgage broker need an AI use inventory?
If you sell to or work with lenders that follow Fannie Mae or Freddie Mac rules, expect to be asked what AI you use. Fannie Mae Section 4 requires an inventory of AI use cases from January 18, 2027, and Freddie Mac Section 1302.8 requires disclosure of AI/ML use on request. A short spreadsheet is enough for a small shop.
Does AI inside my LOS or CRM count?
Yes. Fannie Mae Section 4 also requires managing the risks and governance of third party use of AI, so AI features inside vendor products belong in the inventory.
Is my data sent anywhere when I use this tool?
No. The builder runs in your browser. Rows are kept in this browser on this device until you click Clear all, and nothing is sent to BrokerLumen.
How often should the inventory be updated?
At least once a year with your policy review, and whenever you add a tool or a vendor switches on a new AI feature.