*Posted before Fannie Mae issued Lender Letter LL-2026-04
Freddie Mac Bulletin 2025-16 changed that calculation on March 3, 2026 — quietly, with no grace period, and with enterprise-wide reach that extends to every vendor-embedded tool your institution uses. State-level mandates are already layered on top: Texas TRAIGA is operative now, Colorado’s omnibus AI law takes effect June 30, 2026, and more states are moving.
We’ve built a comprehensive Mortgage Bankers AI Governance Guide at Brody | Gapp. The document attached is a small portion of the release, which summarizes three practice-ready resources available now:
AI Governance Survival Guide — the five-phase governance framework regulators and GSE counterparties will expect to see;
AI Vendor Due Diligence Toolkit — what your vendor contracts almost certainly don’t say, and what they need to; and Fair Lending AI Risk Map — ten AI use cases mapped to specific exposures and the controls that address them;
These aren’t white papers. They’re working frameworks built for compliance, ops, and secondary market teams to apply directly to your current technology stack.
James W. Brody, Esq.
Founding & Managing Partner
Brody Gapp LLP


