Your loan officers are already using AI.
We’ll show you where.
Find shadow AI in your loan officers’, processors’, and underwriters’ workflows. ABT’s AI Readiness Assessment is complimentary for active MWS clients (typically $2,000) and surfaces unsanctioned AI use, audit gaps, and Copilot-readiness blockers in 2 to 3 weeks before you face an FHFA, Fannie Mae, Freddie Mac, or state DFI exam.
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Your loan officers aren’t waiting for IT.
When the approved path is slower than the workaround, loan officers, processors, and underwriters take the workaround. They paste borrower files into ChatGPT on their phones to draft follow-up letters. They summarize closing call notes in free public chatbots. They use browser extensions your tenant has no record of. Most of it never shows up in your audit logs because it never touched your tenant, which is exactly what an FHFA examiner or a Fannie Mae QC reviewer will want to see.
Borrower data walking out the door
A loan officer pastes borrower SSN, income, and address into ChatGPT to draft a borrower letter. The data lands outside your tenant before MERS or Fannie Mae’s QC review knows it left. There’s no record of where it went, how it was retained, or whether the model trained on it.
Audit gaps you can’t close
GSE QC reviewers and FHFA examiners increasingly ask which AI tools your team uses and how you control them. If the answer relies on what employees self-report, you have a finding waiting to happen. A mortgage trust framework needs demonstrable audit trails, not honor-system disclosures.
No examiner trail
An audit-ready AI deployment produces complete logs of what was asked, what borrower data was accessed, and what actions were taken. Shadow AI produces none of that. When MERS data residency rules require tenant-bound processing and the next GSE review asks for evidence, there’s nothing to show.
The lesson regulated industries learned the hard way: unmanaged hidden AI usage is more dangerous than rapid managed deployment, particularly when Fannie Mae, Freddie Mac, and FHFA are issuing AI vendor advisories quarterly. The fastest path to control isn’t prohibiting the tools your people already use. It’s giving them a sanctioned alternative inside your Microsoft 365 tenant, with audit trails and data boundaries that GSE reviewers and state DFI examiners can actually review.
Four pillars. One assessment. Complete picture.
AI readiness is a governance decision, not a licensing decision. ABT evaluates your Microsoft 365 tenant across four dimensions that determine whether Copilot deployment will succeed or create risk for your mortgage operation.
Security Posture
Your Microsoft Secure Score is the starting line. Most mortgage lenders begin around 32%. Guardian clients average above 85%. That gap matters because Copilot amplifies whatever security posture you already have. A low Secure Score with Copilot active means AI can surface board minutes, comp plans, and borrower PII faster than an attacker manually browsing SharePoint. ABT’s assessment reads your actual Secure Score and maps a priority fix list: MFA enforcement, Conditional Access policies, endpoint protection through Microsoft Defender, and Microsoft Entra ID Protection for leaked credential detection.
Data Governance
Copilot respects your permissions. If a junior processor can access the CFO’s SharePoint folder, Copilot can summarize it. That is the problem. Most mortgage lenders, servicers, and GSE-aligned shops have years of accumulated SharePoint permissions that nobody has audited. Sensitivity labels in Microsoft Purview classify documents by risk level. DLP policies block borrower NPI, loan-file PII, and closing-disclosure data from leaving governed boundaries. Retention policies keep data from disappearing when it should not and from lingering when it should not. ABT checks all three before any AI deployment starts.
Identity and Access
Every Copilot query runs under the identity of the person who asked it. If your IT admin has standing Global Admin privileges 24/7, Copilot gives them AI-powered access to everything in the tenant. Microsoft Entra ID with Privileged Identity Management makes admin access time-boxed and auditable. Conditional Access policies enforce where and how loan officers, processors, and underwriters authenticate. Password hash sync with Microsoft Entra ID Protection catches leaked credentials before attackers use them. ABT evaluates all of this because identity is the perimeter for every AI interaction, and an FHFA reviewer will trace authentication evidence back to the loan officer who pulled the file.
Adoption and Training
Technology without adoption is waste. One 100-person mortgage shop deployed Copilot licenses to every employee and found only 9% using it properly after 90 days. The rest either ignored it or used it without understanding what borrower data it could access. Successful deployments start with a champion group of 10 to 15 people, usually a mix of senior loan officers, processors, and underwriters, who learn Copilot’s strengths, document real mortgage use cases, and train their peers. ABT measures adoption by department, tracks which features get used, and adjusts training based on actual behavior. The goal is not just licenses purchased. It is people producing better work.
Get your AI Readiness Assessment
Complimentary for active MWS clients. Includes a tenant scan for shadow AI in your loan officers’, processors’, and underwriters’ workflows, a prioritized 90-day fix list, and an executive readout your board and GSE QC reviewer can review. Senior-engineer engagement, 2 to 3 week delivery.
Your assessment covers eight critical areas
ABT runs the assessment using Microsoft’s automated readiness tooling and Defender for Cloud Apps shadow AI discovery, then layers senior-engineer interpretation on top, tuned to mortgage exam regimes (FHFA, GSE seller-servicer reviews, MERS, state DFI, CFPB). You get a scored report, a prioritized fix list, and an executive readout in 2 to 3 weeks.
Shadow AI Discovery
Microsoft Defender for Cloud Apps identifies every AI service your tenant users have touched in the last 30 days. ChatGPT, Claude, Gemini, and the long tail of free chatbots show up here, including which users and how often.
Data Loss Prevention
Are DLP policies protecting borrower NPI, loan-file PII, and closing-disclosure data? Are sensitivity labels applied to encrypted closing docs and 1003 loan applications? Copilot will surface whatever is accessible, so DLP must be tight before deployment.
Browser Extension Audit
Microsoft Intune and Defender for Endpoint identify which AI browser extensions are installed on managed loan officer and underwriter devices. This is where personal-account ChatGPT signs in alongside corporate Microsoft 365, often invisibly, while LOS data sits in the same browser session.
Secure Score Baseline
Your Microsoft Secure Score compared to mortgage-lender benchmarks. Most lenders start at 32%. Guardian clients average above 85%. We show you the gap and what to fix first.
Tenant Readiness
Microsoft Entra ID configuration, Conditional Access policies, MFA enforcement, PIM for admin accounts, and Purview compliance posture. Identity is the perimeter for every Copilot interaction.
Copilot Utilization Review
Existing Copilot seats in your tenant, who’s using them, and where adoption has stalled. We also identify the most cost-effective licensing path forward, whether that’s Microsoft 365 Business Premium plus Copilot Business or an enterprise stack.
Phased Deployment Plan
A prioritized 30/60/90-day remediation roadmap with assigned ownership, estimated effort, and sequencing. Not a generic checklist. Specific to what your tenant scan revealed.
AI Use Policy + Executive Readout
A draft AI use policy your board can adopt, plus a 30-minute executive readout covering findings, business risk, and recommended next steps. Designed to satisfy GSE QC, FHFA, and state DFI examiner questions before they’re asked.
Two paths in.
The AI Readiness Assessment is a senior-engineer engagement that typically retails at $2,000. ABT runs it complimentary for active MWS clients as part of the Microsoft 365 service relationship.
Complimentary
You’re managing Microsoft 365 with MWS today. The AI Readiness Assessment is included as part of your CSP relationship, scheduled at your timing.
- Two to three week engagement led by an ABT senior engineer
- Eight-component tenant evaluation across security, identity, data governance, AI usage, and deployment readiness
- Microsoft Defender for Cloud Apps shadow AI discovery (every AI service your loan officers, processors, and underwriters touched in the last 30 days)
- DLP and sensitivity-label audit across SharePoint, OneDrive, Teams, and Exchange (covers borrower NPI, loan files, and closing disclosures)
- Microsoft Secure Score baseline plus mortgage-lender peer benchmark
- Custom 30/60/90-day remediation roadmap with assigned ownership and effort estimates
- Draft AI use policy your board can adopt without rewriting
- Executive readout deck plus 30-minute live walkthrough for IT, compliance, and risk leads
- GSE / FHFA / CFPB / MERS / state DFI documentation package
Microsoft 365 not yet with MWS?
Move your Microsoft 365 to MWS during the engagement and the assessment is included. Or scope it as a standalone paid engagement first.
- Move your Microsoft 365 to MWS (ABT Tier-1 CSP) and the assessment is complimentary
- Microsoft 365 Copilot promotional pricing through June 30, 2026 ($10/user/month incremental over Business Premium) becomes available the day you transition
- No-cost CSP transfer support for qualifying mortgage lenders and servicers
- Or scope as a standalone paid engagement ($2,000) and decide afterward
- Same eight-component scope as the active-client engagement
- Senior-engineer-led discovery, interpretation, and executive readout
From assessment to first AI agent in 90 days
ABT manages Microsoft tenants for 750+ financial institutions. This is the path we’ve proven across the mortgage lenders, servicers, and GSE-aligned shops deploying Microsoft 365 Copilot and AI agents.
Assess
Tenant scan plus shadow AI discovery across loan officers, processors, and underwriters. Scored report with prioritized fix list across all four pillars and eight components.
Harden
Guardian deploys security foundations. Secure Score to 85%+, sensitivity labels for closing docs and 1003s, DLP policies for borrower NPI, Conditional Access configured.
Deploy
Microsoft 365 Copilot Business licenses activated. Champion group of senior loan officers and processors trained first. Phased rollout with adoption metrics tracked from day one.
Govern
Microsoft Agent 365 governance controls active. Custom agents deployed via Copilot Studio. Continuous monitoring via Guardian Security Insights, with audit trails ready for FHFA or GSE QC review.
Go deeper on AI readiness
Freddie Mac AI Mandate: A Compliance Checklist for Sellers and Servicers
How the GSE AI advisories translate into tenant-level controls every mortgage lender needs ready before the next QC review.
VENDOR RISKFHFA + Anthropic: AI Vendor Risk for Mortgage Lenders
What FHFA expects when third-party AI tools touch loan files, and how to document the controls examiners will ask for.
COPILOT DEPLOYMENTMicrosoft Copilot for Mortgage Operations: A Deployment Guide
Where Copilot moves the needle in origination, processing, and underwriting, and how to deploy without surfacing data the wrong way.
Frequently asked questions
Find your shadow AI.
Tell us about your institution and we’ll show you exactly which AI tools your loan officers, processors, and underwriters are using today, how they map to FHFA, GSE, and state DFI examiner expectations, and what it takes to bring them inside your tenant.

