Governing Personal-Agent Traffic in Mortgage: Model Risk, Fair Lending, UDAAP and the Audit Trail
When borrowers' agents start talking to a lender's systems, the lender has a new channel to govern — one where the other party is software, the lender's own agent may be answering, and the record of what happened is easy to lose. How existing frameworks apply: GSE AI governance requirements, model risk and third-party risk guidance, ECOA and fair lending, UDAAP, and record retention under Regulation B and Regulation Z.