The industry is auditing the wrong half of the lending stack
BRODY | GAPP LLP is a national mortgage banking compliance, litigation, and technology law firm representing independent mortgage banks, depositories, credit unions, mortgage brokers, and fintechs in regulatory compliance, repurchase and make-whole defense, mortgage fraud investigation and recovery, employment and business tort litigation, and strategic transactions. The firm is headquartered in Irvine, California, with a fully remote national practice.
The industry is auditing the wrong half of the lending stack
Old statutes, new models, and the vendor contract you signed before machine learning became operational
New GSE rules are pushing mortgage lenders to conduct deeper audits of vendor AI systems beyond traditional SOC 2 reviews
As regulatory scrutiny intensifies, lenders must prove AI systems are transparent, compliant, and defensible across the mortgage lifecycle