AI Adoption: GSE Governance & Compliance Review
AI is becoming an integral part of mortgage lending, but the expectations for managing it have changed.
Fannie Mae now expects Seller/Servicers using AI or machine learning in covered origination or servicing activities to establish governance around its use. That includes clear ownership, documented policies, risk management, legal and regulatory considerations, third-party oversight, and the ability to explain how AI is being used and safeguarded.
Freddie Mac approaches AI within a broader information-security and operational-risk framework. Its requirements address responsibility for security controls, AI-related training and threats, third-party risk, monitoring, and incident response, including documented response plans for AI/ML incidents.
Lenders need to know where AI is being used, understand the risks it creates, establish accountability and controls, and be prepared to demonstrate that those risks are being managed.
Practical Roadmap for Responsible AI Adoption
We help you gain GSE regulatory confidence to accelerate AI innovation and gain business efficiencies.
Inventory AI Tools
Assess AI Usage Occasions
Govern AI Processes
Demonstrate
Overisght
Identify where AI and machine learning are being used across your organization, including third-party and vendor solutions.
Establish a clear view of each use case, its purpose, and where it touches mortgage operations.
Evaluate each AI use case for regulatory, operational, data, vendor, and other relevant risks.
Identify gaps between current practices and GSE expectations.
Put the policies, ownership, controls, oversight, and ongoing review processes in place to manage AI responsibly.
Extend those governance expectations to vendors and subcontractors.
Maintain the documentation and evidence needed to show how AI is being used and how associated risks are being managed. Be prepared to disclose AI use, purpose, safeguards, and other requested information to the GSEs.