If a vendor wants to sell you “AI,” don’t start with the demo. Start with the rules.
In mortgage lending, you are responsible for what your vendors do with borrower data and how their tools influence decisions.
A strong AI vendor questionnaire should focus on four things: privacy, fairness, explainability, and consistency, because those are the areas regulators care about most.
But you don’t need to start with an exhaustive list of questions. This article will give you the top things to ask for to filter-out tech that will never meet your Compliance team’s requirements.
“AI” is everywhere in mortgage tech right now.
Some tools talk to borrowers. Some summarize documents. Some flag conditions. Some recommend next steps. Some try to predict fallout, compliance risk, or likelihood to close.
A lot of that sounds harmless until you remember one simple truth:
In mortgage lending, small decisions stack up.
A message to a borrower. A document classification. A flagged exception. A suggested condition. A recommended product. A timing change in disclosures. A call script. A lead priority score.
None of those things may look like underwriting by themselves. But together, they can influence who gets help, who gets fast service, who gets a second look, and who gets denied.
The CFPB has been clear that lenders can’t hide behind “complex algorithms” when they take an adverse action (like denying a loan or offering worse terms). If your system can’t explain the real reasons, that’s a problem.
Also, the government has warned that “automated systems” are not an excuse for discrimination. If a tool creates unfair outcomes, the lender can still be held responsible.
So here’s the mindset shift:
Buying AI isn’t just buying software. It’s adding a decision-maker, or, at a minimum, a decision influencer, to your workflow.
And decision-makers must follow mortgage rules—every time, for every borrower.
Mortgage lending already has strict requirements. AI doesn’t replace those requirements. AI raises the standard, because it can scale mistakes fast.
When a lender uses AI anywhere in origination, regulators will expect the lender to prove four things:
AI can absolutely help lenders move faster and lower costs. It can reduce “stare-and-compare” work, speed up document handling, and guide teams to exceptions instead of forcing them to touch every file. (That’s the good version of automation: let clean loans move, and route problems to the right people.)
But speed without guardrails creates a different kind of cost: complaints, cures, buybacks, and reputational damage.
So the goal isn’t “use AI.” The goal is:
Use AI in a way you can defend.
Defend to a borrower. Defend to an auditor. Defend to a regulator.
That starts with your questionnaire, not a fancy demonstration.