AI Acceptable Use Policy

Effective Date: December 9, 2025
Last Updated: December 10, 2025

The purpose of this policy is to outline the acceptable use of AI systems and technologies within Kearns Mortgage Team, LLC. These rules are in place to protect the employee and the company from risks including ethical concerns, legal liability, and misuse of AI technologies.

Scope

This policy applies to:

• All employees of Kearns Mortgage Team, LLC
• All contractors of Kearns Mortgage Team, LLC
• All vendors, third parties, and visitors who temporarily use Kearns Mortgage Team, LLC AI systems and technologies

Background

The AI Acceptable Use Policy outlines the rules for using AI systems and technologies for business purposes. The rules in this policy are written to ensure ethical, legal, and responsible use of AI technologies and to prevent misuse that could harm individuals or the company.

Policy

• Under no circumstances is an employee authorized to engage in any activity that is illegal under local, state, federal, or international law while utilizing AI systems and technologies.
• The use of AI systems and technologies must be strictly for the Company’s business purposes.

General Use and Ownership

While the Company desires to provide a reasonable level of privacy, users should be aware that the data they create using AI systems and technologies remains the property of the Company. Because of the need to protect the Company’s network and information assets, management cannot guarantee the confidentiality of personal information stored by employees on any AI system or device belonging to the Company.

Prohibited Activities

• Users must not engage in any activity involving AI systems that is illegal, unethical, or violates company policies.
• Users must not use AI systems to generate or distribute content that is harmful, discriminatory, or abusive.
• Users must not manipulate any systems to incorporate AI capabilities without proper authorization.

Security Measures

• Users must ensure that their AI systems and technologies have up-to-date security measures and patches.
• Users must report any suspicious activity or security incidents related to AI systems to the IT department immediately.

Acceptable Use Guidelines

• Users must use AI systems and technologies for legitimate business purposes only.
• Personal use of AI systems is permitted if it does not interfere with work responsibilities or violate company policies.
• Users must adhere to ethical guidelines and best practices for AI usage.

Verification Protocol

Whenever an AI response seems incorrect, inconsistent, or “doesn’t sound right,” especially in high-impact contexts, follow the steps below.

• Pause use and sharing of the output until verification is complete.
• Isolate the core assertions (facts, recommendations, steps) and identify what must be true for the answer to be correct.
• Verify against authoritative sources (internal documentation, official standards, trusted third-party references); do not rely on the AI alone.
• Assess Acceptable Use Policy alignment to ensure the response does not introduce harm, policy violations, privacy exposure, bias, or prohibited guidance.
• Resolve the outcome:
  • Approve if verified and compliant.
  • Revise if partially correct but requires safer wording or constraints.
  • Reject/Escalate if unverified, incorrect, or AUP-conflicting.
• Document the check (what was reviewed, sources used, decision made) and adjust prompts/guardrails if similar issues recur.

Compliance with Regulations

• The use of AI systems and technologies must comply with all relevant laws and regulations.
• Users must adhere to the Company’s data protection and privacy policies when using AI systems.

Monitoring and Enforcement

• The Company reserves the right to monitor AI system usage to ensure compliance with this policy.
• Violations of this policy may result in disciplinary action, up to and including termination of employment.

Training and Awareness

• The Company will provide training and resources to educate users about this policy and promote ethical AI usage.
• Users are encouraged to stay informed about best practices for responsible AI usage.

Policy Review

This policy will be reviewed annually and updated as necessary to ensure it remains effective and compliant with legal requirements.

Additional Compliance Requirements

Fair Lending and Anti-Discrimination Compliance

All AI usage that supports or influences any mortgage-related activity must comply with the Equal Credit Opportunity Act (ECOA), Regulation B, the Fair Housing Act (FHA), and all applicable federal and state fair lending laws. AI tools must not be used in any manner that could introduce discrimination or result in inconsistent treatment of applicants or protected classes.

Non-Public Personal Information (NPPI) and Data Protection

Employees must not enter or upload borrower-specific NPPI into any AI system unless that system has been approved for such use. NPPI includes information protected under GLBA and FCRA such as Social Security numbers, addresses, dates of birth, bank statements, tax returns, and other consumer financial information.

Human Review for Borrower-Facing Outputs

All AI-generated borrower-facing communications must undergo human review. AI cannot replace required regulatory judgment or compliance checks.

Use of Authorized AI Tools Only

Employees may use only Company-approved AI tools. Unapproved platforms may not be used for business activities or to process Company data.

Vendor and Model Change Management

Material changes to AI systems or vendors must be reviewed and approved to ensure continued compliance with Company standards and applicable regulations.

Incident Response and Security Events

Any AI-related incident must be reported immediately and handled according to the Company’s Incident Response and Data Breach Notification Policy.

Prompt Hygiene and Responsible Input Practices

Employees must avoid entering sensitive information into AI tools unless explicitly permitted. Placeholder data should be used during testing or prompt development.

Accuracy and Non-Deception Standards

AI must not generate misleading, deceptive, or unsubstantiated content. All outputs must be verified before use.

Roles and Responsibilities

The Company will designate personnel responsible for AI governance, reviewing new tools, approving system changes, and responding to AI-related concerns. Employees must follow instructions from authorized personnel.

Adverse Action Determinations

AI systems may not generate or determine adverse action reasons. All adverse action disclosures must be human-validated and compliant with Regulation B.

Documentation and Recordkeeping

Employees must document material AI-assisted decisions and verification steps according to Company recordkeeping requirements.

Automated Valuation Model (AVM) Compliance

If AI or automated systems are used to support valuation activities, they must comply with federal AVM rules, including bias mitigation, quality controls, and documentation standards.

Human Judgment and Legal Obligations

AI cannot replace professional judgment, licensing obligations, or legal responsibilities. Employees remain fully accountable for ensuring compliance with all applicable laws.

Prohibition on Synthetic Media and Unauthorized Representations

Employees may not create or distribute AI-generated depictions of real individuals without explicit authorization.

Non-Retaliation for Reporting Concerns

Employees who report AI-related concerns in good faith will not face retaliation.

Alignment with Industry Best Practices

The Company aims to align its AI practices with emerging standards, including the NIST AI Risk Management Framework, to ensure responsible AI use.

Contact Information

If you have questions about this AI Acceptable Use Policy, need clarification about approved AI tools, or wish to report a concern, please contact:

Kearns Mortgage Team, LLC
AI Compliance & Security Administration
3903 Northdale Blvd., Suite 100E
Tampa, FL 33624
Email: Hello@kearnsmortgageteam.com
Phone: 813-796-5755

Employees may also report AI-related issues directly to management or through designated internal reporting channels. Reports made in good faith will not result in retaliation.