Uniquely TMC 2026 recap: mortgage compliance takeaways

State examiners are asking mortgage lenders for more documentation, reaching further into social media, and preparing to test how lenders govern AI. That was the clearest message I heard at Uniquely TMC, The Mortgage Collaborative’s conference in Austin on September 20–22, 2026.

The backdrop matters. Lender M&A activity was reported as rising, from about 37 deals in 2024 to about 62 in 2025, and smaller lenders are still losing money on production. Compliance teams are covering more states, channels, and technology with the same headcount or less.

Perhaps the most useful hour of the week was a compliance peer session led by Katherine Hollister, Chief Compliance Officer of Jet Home Loans & ActiveComply’s own Asif Alam. Lenders compared notes on what examiners are requesting right now. Five themes came up again and again.

State exams are getting broader and deeper

Examiners are requesting more, and they are coming back for follow-ups. One lender licensed in 49 states delivered zip files of every ad, print piece, and social post, organized by state. Another saw a 120% increase in information requests between back-to-back North Carolina exams.

States are also sharing and cross-checking data. Arizona used California’s exam findings directly against a lender, the first case the group had personally seen. Texas is comparing call reports against HMDA data and requiring refiling when they do not match. And some examiners were requesting full records of loan-file communications, including emails, texts, and calls that happen outside the loan origination system.

Social media risk does not leave when the loan officer does

Departed loan officers often leave outdated LinkedIn, Facebook, and personal website content live. Lenders in the group reported that Illinois, North Carolina, Texas, Nevada, and Virginia regulators are all flagging it in exams.

Two related findings came up more than once. New hires are posting that they are “licensed” before the license is active. And overlap between personal and professional accounts, such as political or religious posts, is creating brand and potential fair lending exposure.

Fair lending is the most underestimated risk

The federal posture is quieter right now with the recent Reg B feedback on disparate impact, but the group expects fair lending enforcement to return with a vengence of examination look-back periods. It was also noted that state attorneys general and private rights of action remain active regardless.

The practical exposure is pricing concessions, the reason for a concession is not consistenly captured in the loan file. The group’s recommendations: ensure there are a limited-few decision makers who can allow for pricing exceptions & keep separate underwriting and pricing exception logs that record approvals, denials, and the reason for each.

AI governance is moving from policy to proof

AI adoption is running well ahead of governance, and the standards are catching up. In June, MISMO released FRAME (Framework for Responsible AI in the Mortgage Ecosystem). On September 16, CSBS released its Artificial Intelligence Supervisory Framework, which gives state examiners a tool for assessing AI governance at state-licensed nonbank lenders.

The room agreed on one principle: if AI causes a compliance error, the lender owns it. The unsolved problem is shadow AI, meaning loan officers using personal devices and consumer AI accounts outside any monitored system.

One lender’s answer was the most concrete idea of the week. It tied its AI policy to payroll, and staff had to disclose every AI tool they used before payroll would release. That step surfaced dozens of undisclosed tools, and the lender then narrowed its approved list to two.

Regulators are still building their own capacity. At the AARMR conference, roughly 75% of state examiners I spoke to said they do not yet have an AI governance framework of their own. The remaining 25% or so were highly aware of the risks and had taken proactive steps to invest in their technical examination programs. Consumer-facing chatbots were named the highest-risk use case, because they can drift into solicitation or pricing discussions without guardrails.

Vendor AI Use Cases with Pros & Cons

One lender’s QC vendor quietly switched from human review to AI-based review. Monthly findings jumped from 3–5 to more than 30, with inconsistent severity ratings on identical issues. It took two months of calls to sort out.

The group’s vendor AI questionnaires come down to three questions: What is the tool used for? Does it touch consumer data? Does it render financial decisions?

Not every AI story was cautionary. One lender outlined that they were currently running an agentic AI overlay in shadow mode alongside live underwriting, with a 2% error threshold before any decisioning goes live. In testing, the AI is making fewer mistakes than human processors, and the goal is to move closing QC from 10% file sampling to full coverage.

What to do before your next exam

The group’s advice was practical: keep a standing exam folder that is always current, and produce exactly what is asked for and nothing more. Based on what we heard, here is our recommended checklist for that folder:

• Advertising materials, archived by state, including print, digital, and social
• Social media archives, including accounts tied to former loan officers
• Policies and procedures, including your AI governance policy and approved tool list
• Training logs, with policy sign-offs
• Exception logs for underwriting and pricing, with reasons for approvals and denials
• Vendor oversight records, including AI disclosures and questionnaire responses

The shift is clear. Saying “we use AI” or “we monitor social” will not satisfy an examiner for much longer. Lenders will need to show their work.

See how ActiveComply helps

ActiveComply^® Social and ActiveComply Web help mortgage lenders monitor loan officer social media and websites. ActiveComply Pre-Review routes advertising materials through a documented review and approval workflow, so the record is organized when an examiner asks for it. Talk with our team about keeping your exam folder current as examiner requests grow.

Frequently asked questions

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For more, see our mortgage compliance exam FAQ.