IR Readiness for New Freddie Mac AI/ML Guidelines

In December 2025, Freddie Mac issued Bulletin 2025-16,  introducing a new governance framework requirement for the use of artificial intelligence (AI) and machine learning (ML) by mortgage sellers/servicers. The new requirements, effective March 3, 2026, are designed to ensure the ethical, transparent, and safe deployment of AI in the mortgage industry.  

Key tenets of the framework include:

• Lender implementation of formal policies, risk assessments, and oversight for AI systems used in underwriting, fraud detection, or customer-facing decisions
• Senior management accountability (e.g., Chief Information Officer, Chief Technology Officer, or Chief Risk Officer) sign-off on the lender’s AI policies
• Defined guardrails to prevent unethical use and protect against AI-specific threats like model inversion, data poisoning, and prompt injection
• Separating responsibilities to prevent conflicts of interest, ensuring that those who benefit from AI systems are not solely responsible for defining and measuring their risks
• Continuous monitoring and documentation, including annual reviews of AI policies and documentation to demonstrate compliance

AI at Informative Research

IR stands ready to comply with the revised Freddie Mac guidelines and to support lenders in developing their AI frameworks by transparently disclosing how we leverage AI to fulfill services (credit reports, verifications, etc.) to the industry.

Today, IR leverages AI and ML for efficiencies in non-decisioning functions such as:

• User authentication and identity detection
• Document and workflow management
• General operational automation
• Market and financial analysis
• Product analytics and customer segmentation
• Customer support

Currently, IR does not utilize AI and ML in decisioning functions (any processes that make or support a determination about a consumer), such as:

• Credit merge logic
• Tradeline updates or analysis
• Supplement compilation and fulfillment
• Letter of explanation compilation and fulfillment
• Consumer dispute investigation and resolution
• Employment or income data aggregation

As AI technology becomes increasingly ubiquitous and reliable, IR will evaluate additional internal use cases that streamline our operations and service delivery. Any fundamental shift in the use of AI in our decisioning functions will be communicated to our client base in a clear and documented manner.