YOUR COMPLIANCE QUESTION
We are using your AI Policy Program. Upon receipt, we had it reviewed by our AI committee to determine whether it complies with Freddie's requirements for establishing a comprehensive AI governance framework for AI and Machine Learning.
I am pleased to report that your AI Policy Program received the committee's approval. It met our checklist based on Freddie's requirements.
As a Freddie Mac Seller/Servicer, we want to know what the effect would be on us if we had relationship partners that are not in compliance with the AI governance framework.
What restrictions will Freddie Mac impose on us if our relationship partners do not comply with their AI requirements as of March 3, 2026?
Signed,
An Anxious Compliance Manager
OUR COMPLIANCE SOLUTION
AI POLICY PROGRAM FOR MORTGAGE BANKING™
Our AI Policy Program aligns with Freddie Mac's AI governance requirements for the Freddie Mac Seller/Servicer (or "Lender"). Our well-constructed AI Policy Program is a proactive means designed to avoid and mitigate risks associated with Artificial Intelligence and Machine Learning. Responsible AI practices can help align AI system design, development, and use with applicable legal and regulatory guidelines.
Our AI Policy Program consists of the following policies:
1. Artificial Intelligence Governance Policy
2. Artificial Intelligence Use Policy
3. Artificial Intelligence Workplace Policy
4. Artificial Intelligence Credit Underwriting Policy
5. Artificial Intelligence Do & Do Not Policy
6. Artificial Intelligence Ethics Policy
7. Artificial Intelligence Vendor Management Policy
Discount offer available until March 3, 2026!
Contact us for the presentation and pricing.
OUR RESPONSE TO YOUR QUESTION
Thank you for using our AI Policy Program. Since its release on October 30, 2025, it has been in considerable demand.
Our AI Policy Program for Mortgage Banking™, which meets Freddie Mac's AI Governance Framework ("AI Framework"), is the first to provide a set of AI policies dedicated to mortgage banking.
We had been tracking the GSE formulation of AI requirements for several months.
On March 11, 2025, Freddie released a formal AI/ML governance framework in its Seller/Servicer Guide ("Guide"), introducing a comprehensive AI Framework for Sellers and Servicers that requires formal policies for the use of artificial intelligence ("AI") and machine learning ("ML"). This update mandated that any AI/ML used in the origination or servicing of Freddie Mac-eligible loans be governed by strict policies.
On December 3, 2025, Bulletin 2025-16 was issued, clarifying timelines and expectations and stating that AI is no longer optional. In effect, Freddie asserted that implementation is a mission-critical, governed enterprise function.
The compliance effective date is March 3, 2026.
After considerable review, research, and drafting, we issued our AI Policy Program on October 30, 2025, thirty-four days before Freddie issued Bulletin 2025-16 on December 3, 2025, and Bulletin 2025-17 issued on December 10, 2025.
On December 10, 2025, Freddie issued Bulletin 2025-17, which introduced revisions to AI Tools relating to servicing, information security, and Seller/Servicer insurance, with most changes effective on March 3, 3026.
In the context of the AI Framework, "AI Tools" are any artificial intelligence or machine learning tools used in the loan lifecycle.
BULLETINS
Bulletin 2025-16 solidifies the compliance effective date of March 3, 2026, requires Lenders to have a comprehensive governance framework for AI/ML Tools used in loan origination or servicing, and, effective January 1, 2026, Lenders must ensure executive oversight, document AI use cases, ensure fairness, mitigate bias, and manage vendor risk.
