Editor’s Note: Law Firm Launches Mortgage AI Governance Audit Practice
Brody | Gapp LLP, a national mortgage banking compliance, litigation, and AI governance law firm, launched its Mortgage AI Governance Audit Practice and set a Q3 2026 publication date for The Mortgage Bankers AI Governance Guide™, which was conceived by Founding and Managing Partner James W. Brody and co-authored with Founding Partner Ronald Gapp, Jr.
Friday Harbor, the Seattle-based AI pre-underwriting platform, has become the first mortgage technology provider to complete the firm’s Limited Attestation. The engagement, initiated by Friday Harbor before any regulator compelled it, evaluated the platform across fair lending, adverse action under Regulation B §1002.9, model governance, vendor risk management, data governance, internal controls, and examination readiness.
The launch arrives as Freddie Mac’s AI risk management requirements under §§1302.2 and 1302.8 are in effect and Fannie Mae Lender Letter LL-2026-04 — which requires lenders to satisfy themselves that vendors operating AI systems on their behalf are subject to controls no less protective than the lender’s own — becomes effective August 6, 2026.
“On one side, binding AI governance requirements are already in effect at Freddie Mac, with Fannie Mae’s own set of requirements coming online in August. On the other, very few lenders are positioned to produce defensible governance files today,” said Mr. Brody. “Friday Harbor stepped forward as an early example for the benefit of their lender customers and the industry before any regulator forced the question.”
The Mortgage Bankers AI Governance Guide is a practitioner reference guide that maps out every material AI deployment at a fictional Independent Mortgage Bank, walks through each of the anticipated AI governance issues that will be encountered throughout the mortgage lifecycle, and provides insightful guidance on how lending institutions can make their AI deployments defensible – with tailored insights for CEOs, GCs, Compliance Officers, HR, Secondary, and more. “We built the Guide around what a compliance committee needs to produce when a demand letter, an examination request, a QC self-report, or a discovery production lands,” said Mr. Gapp, a former general counsel and chief operating officer of a national multi-channel lender.
Friday Harbor, the Seattle-based AI pre-underwriting platform named to HousingWire’s 2026 Tech100 Mortgage list, has become the first mortgage technology provider to complete the firm’s Limited Attestation. The engagement, initiated by Friday Harbor before any regulator compelled it, evaluated the platform across fair lending, adverse action under Regulation B §1002.9, model governance, vendor risk management, data governance, internal controls, and examination readiness.
The launch arrives as Freddie Mac’s AI risk management requirements under §§1302.2 and 1302.8 are in effect and Fannie Mae Lender Letter LL-2026-04 — which requires lenders to satisfy themselves that vendors operating AI systems on their behalf are subject to controls no less protective than the lender’s own — becomes effective August 6, 2026.
“On one side, binding AI governance requirements are already in effect at Freddie Mac, with Fannie Mae’s own set of requirements coming online in August. On the other, very few lenders are positioned to produce defensible governance files today,” said Mr. Brody. “Friday Harbor stepped forward as an early example for the benefit of their lender customers and the industry before any regulator forced the question.”
The Mortgage Bankers AI Governance Guide is a practitioner reference guide that maps out every material AI deployment at a fictional Independent Mortgage Bank, walks through each of the anticipated AI governance issues that will be encountered throughout the mortgage lifecycle, and provides insightful guidance on how lending institutions can make their AI deployments defensible – with tailored insights for CEOs, GCs, Compliance Officers, HR, Secondary, and more. “We built the Guide around what a compliance committee needs to produce when a demand letter, an examination request, a QC self-report, or a discovery production lands,” said Mr. Gapp, a former general counsel and chief operating officer of a national multi-channel lender.
Tony Garritano is the founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 20 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting PROGRESS in Lending Association was the next step for someone like Tony, who has dedicated his entire career to providing mortgage executives with the information that they need to make informed technology decisions to help their businesses succeed.
