Mortgage AI Policy Template: Free AI Acceptable Use Policy

Last reviewed: October 27, 2026. Free to copy and adapt. No email required. This is a starting template, not legal advice. Have your counsel review it before you adopt it.

An AI acceptable use policy tells your team which AI tools they may use, what they may put into them and what must be checked by a person. For a mortgage company, the core issue is borrower data. This template is written around that, and around the governance themes in Freddie Mac Guide Section 1302.8 and Fannie Mae Supplement Section 4: senior approval, staff communication, a named owner, annual review, vendor oversight and disclosure on request.

How to use this template

Copy the policy below and paste it into your word processor.
Replace every item in [BRACKETS].
List your approved tools and what each may be used for.
Have your senior leader approve it and date it.
Have every person who uses AI read and sign it, and repeat each year.

[COMPANY NAME] AI Acceptable Use Policy

Version [1.0]. Effective [DATE]. Policy owner: [NAME, TITLE]. Approved by: [NAME, TITLE] on [DATE]. Next review: [DATE, no later than 12 months after approval].

1. Purpose and scope

This policy sets rules for using artificial intelligence (AI) tools at [COMPANY NAME]. It applies to all employees, loan officers, processors, contractors and anyone else who works on our behalf, on any device, whenever the work involves our business, our borrowers or our loan files.

2. Definitions

AI tool: any software that generates, analyzes or summarizes content or makes or suggests decisions, including chatbots, writing assistants, transcription and note takers, and AI features inside our LOS, CRM, pricing and marketing tools.
Borrower data: any nonpublic personal information about an applicant or borrower, including names with financial details, Social Security numbers, account numbers, income, assets, credit information and loan documents.
Approved tool: an AI tool listed on our Approved AI Tools List for the uses shown there.

3. Approved tools

Use only approved tools for company work. The policy owner keeps the Approved AI Tools List, including the tool, the approved uses, whether borrower data is allowed, and the date approved. To request a new tool, email [OWNER EMAIL]. Do not sign up for AI tools with company accounts or connect them to company systems until they are approved.

4. Allowed uses

Drafting general marketing content, emails and social posts that contain no borrower data.
Summarizing public information, such as published guidelines, for internal use.
Brainstorming, editing and formatting internal documents.
Uses listed on the Approved AI Tools List.

5. Uses that need approval first

Any use that involves borrower data.
Any AI output sent to a borrower, a lender or an investor.
Any AI feature that analyzes loan files, documents or income, or that suggests pricing, eligibility or underwriting outcomes.
Any new AI feature a vendor turns on in a tool we already use.

6. Prohibited uses

Entering borrower data into any AI tool that is not approved for borrower data.
Letting AI make or communicate a credit decision, pricing decision or adverse action without human review.
Using AI to impersonate a person, create fake documents or alter loan documents.
Using AI in a way that treats applicants differently on a prohibited basis.
Sharing passwords, system access or confidential company information with an AI tool.

7. Human review

A person reviews AI output for accuracy, fairness and tone before it is used in a loan file or sent outside the company. The person who sends it is responsible for it.

8. Confidential information

Treat AI output created from borrower data or other confidential information as confidential, with the same handling, storage and retention rules as the source data.

9. Vendors

Before approving a tool, the policy owner asks the vendor how its AI uses our data, where it is processed, whether it is used for training, how long it is kept, and how incidents are reported. Answers are filed with the Approved AI Tools List and checked at contract renewal.

10. AI use inventory

The policy owner keeps an inventory of each way we use AI: the tool, purpose, data used, owner, risks and safeguards. The inventory supports any request from a lender, investor or regulator to describe our AI use.

11. Incidents

Report any suspected AI-related problem to [OWNER EMAIL] right away, including borrower data entered into an unapproved tool, inaccurate AI output that reached a borrower, or a vendor AI incident. The owner follows our incident response procedures.

12. Training and acknowledgment

Everyone covered by this policy reads it and signs an acknowledgment before using AI for company work, again each year, and again when the policy changes. Records of acknowledgments are kept for [RETENTION PERIOD].

13. Review and enforcement

The policy owner reviews this policy at least once a year and when laws, investor requirements or our tools change. Violations may lead to loss of tool access and other discipline up to termination.

Acknowledgment

I have read and understand the [COMPANY NAME] AI Acceptable Use Policy and agree to follow it.

Name: ____________________ Signature: ____________________ Date: __________

Free generic template, this template, or the $99 AI Policy Starter

Generic AI policy templates are written for any industry and vary widely. This page gives you a mortgage-specific policy for free. The $99 AI Policy Starter adds the files that turn a policy into a program you can show a lender.

What you get	Generic free AI policy template	This free mortgage template	$99 AI Policy Starter
Written for mortgage borrower data	Varies; written for any industry	Yes	Yes
Human review before AI output reaches a borrower	Varies	Yes	Yes
Owner, senior approval and annual review fields (1302.8 and Section 4 themes)	Varies	Yes	Yes
Editable Word file	Varies	Copy and paste	Yes
15-point AI readiness checklist	Varies	Free web version	Yes
Staff acknowledgment form	Varies	Short signature line	Yes
Approved AI tools list	Varies	Referenced only	Yes
Staff sign-off tracking	Usually not included	Use the Free portal, up to 10 staff	Use the Free portal, up to 10 staff
Price	$0	$0	$99 one-time

Track who signed it

A policy only helps if you can show who read it. The BrokerLumen portal is free for up to 10 staff, with timestamped sign-offs and status tracking. Start the Free plan.

Next, check your gaps with the AI policy checklist for brokers and lenders, or read what an AI policy for mortgage brokers should cover.

Want the editable files and the checklist?

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

Is this AI acceptable use policy template really free?

Yes. Copy it and adapt it for your company. No email or sign-up is required.

Is the template aligned to Fannie Mae and Freddie Mac?

It is written around the governance themes in Freddie Mac Guide Section 1302.8 and Fannie Mae Supplement Section 4, such as senior approval, staff communication, a named owner and annual review. It is a starting point and needs counsel review before adoption.

What does the $99 AI Policy Starter add?

An editable starter AI acceptable use policy, a 15-point AI readiness checklist, a staff acknowledgment form and an approved AI tools list. Use it with the Free portal plan for up to 10 staff.

Does an acceptable use policy cover everything Fannie Mae and Freddie Mac ask for?

No. Both also expect broader governance, such as an inventory of AI uses, vendor oversight and risk assessment. The AI Policy Kit covers those documents.

Free mortgage AI acceptable use policy template