AI did not enter the mortgage operation through a formal procurement process. It entered through vendor platform updates, marketing tools, embedded ML features in your LOS, and employees using consumer AI on personal devices. The result: most depository institutions have more AI touchpoints than they realize — and governance programs that were built for traditional models, not for the AI tools now in production.
This reference addresses the regulatory framework, examination expectations, and governance architecture that depository institutions — banks regulated by the OCC, FDIC, and the Federal Reserve — need to address. It is designed to complement, not replace, your existing model risk management and cybersecurity governance programs.
