Institutions

Built for the institutions that finance America.

Residential mortgages and the real estate they finance form the largest asset class on earth — over $13 trillion in outstanding debt held across thousands of institutions, from member-owned credit unions to the government-sponsored enterprises themselves. Every one of them now needs a control system for automated valuations.

AVMS.AI is that control system — engineered for the regulatory complexity, examination rigor, and operational scale of every institution type the AVM Final Rule covers.

OCC · Federal Reserve · FDICNCUA · CFPB · FHFASix agencies. One rule. One platform.
The Regulatory Apparatus

Six federal agencies. One mandate.

The Interagency AVM Quality Control Rule was issued jointly by every federal agency with supervisory authority over mortgage lending and securitization. Your institution's primary regulator will examine your AVM controls under its own examination framework — but the standard is the same across all six.

OCC

Office of the Comptroller of the Currency

National banks and federal savings associations

FRB

Federal Reserve Board

State member banks and bank holding companies

FDIC

Federal Deposit Insurance Corporation

State nonmember banks and insured state savings associations

NCUA

National Credit Union Administration

Federal credit unions and federally insured state credit unions

CFPB

Consumer Financial Protection Bureau

Non-depository mortgage originators and large depository institutions

FHFA

Federal Housing Finance Agency

Fannie Mae, Freddie Mac, and the Federal Home Loan Banks

01Community Banks & Credit Unions

Smaller institutions. Same regulatory standard.

The AVM Final Rule does not exempt institutions by asset size. A $200 million credit union processing fifty AVMs a year faces the same five-factor requirement as a national bank processing fifty thousand. The difference is that the credit union has two people in compliance, not two hundred.

Community banks regulated by the OCC, FDIC, or state banking departments and credit unions regulated by the NCUA need a control system that delivers institutional-grade compliance without requiring institutional-grade headcount. The platform provides regulatory-body-specific policy defaults during onboarding — so a NCUA-regulated credit union starts with the right configuration from day one.

Document upload and batch tape are the primary intake methods for this segment. No API integration required. No IT project. Upload your loan documents and AVM reports, and the protocol does the rest.

Regulatory Context
Credit unions: NCUA examination framework
Community banks: OCC or FDIC depending on charter type
State-chartered institutions: dual oversight (state + federal insurer)
Asset threshold: no minimum — the rule covers all covered transactions
Examination Pressure
NCUA examiners increasingly focused on third-party risk management
OCC heightened standards for institutions using model-based valuations
Limited compliance staff makes manual QC programs unsustainable
Examiner expectation: documented, operational, demonstrable controls
Platform Fit
Standard plan ($18K/yr) — purpose-built for this segment
Document upload + batch tape — no integration required
Regulatory-body-specific defaults during onboarding
Full five-factor compliance from the first loan processed
Examiner package: one-click ZIP with all compliance evidence
Regulatory Context
OCC-regulated: heightened standards, continuous monitoring expectations
Federal Reserve: SR letters on model risk management (SR 11-7)
Multi-state operations: compliance across multiple jurisdictions
Board-level reporting: AVM governance as a risk committee agenda item
Operational Scale
Hundreds to thousands of AVM-backed decisions per day
Multiple origination channels (retail, wholesale, correspondent)
Multi-vendor AVM strategies requiring normalized comparison
Branch-level analytics and geographic concentration monitoring
Platform Fit
Professional ($48K/yr) or Enterprise ($96K/yr) plans
REST API integration embeds compliance in the LOS workflow
SFTP for automated nightly batch processing
SSO + unlimited team members + multi-branch management
Per-MSA nondiscrimination drill-down for CRA and fair lending
Vendor firewall with whitelist mode for approved-only operations
02Regional & National Banks

Enterprise scale. Protocol-grade evidence.

Regional and national banks operate under the most intensive supervisory frameworks in American banking. OCC-regulated institutions face heightened standards for model risk management. Federal Reserve-supervised institutions operate under SR 11-7 guidance that treats AVMs as models requiring governance, validation, and ongoing monitoring.

At this scale, AVM compliance is not a back-office function — it is a risk committee agenda item. The board needs to see that the institution's AVM controls are documented, tested, and producing verifiable evidence. The platform provides that evidence automatically, across every origination channel and every AVM vendor, with the cryptographic proof that the controls were followed.

API integration embeds compliance validation directly in the loan origination workflow — the compliance check happens at the point of decision, not in a post-closing review six weeks later. SFTP enables automated nightly processing for institutions that prefer file-based integration.

03Mortgage Lenders & Correspondents

State-licensed originators. Federal obligations.

Non-depository mortgage lenders and independent mortgage banks are regulated by the CFPB for AVM quality control purposes, alongside state licensing requirements. The AVM Final Rule applies to every covered transaction — purchase, refinance, and HELOC originations where an AVM informs the credit decision.

Correspondent lenders face a dual obligation: their own compliance with the rule as originators, and the requirement to deliver loans that satisfy the aggregator's AVM governance standards. The platform produces loan-level compliance proofs that travel with the loan file — evidence that the originator's controls were followed before the loan was sold.

For lenders selling into the secondary market, the compliance receipt becomes a competitive advantage. An aggregator choosing between two loan packages — one with cryptographic compliance proofs and one with a spreadsheet — will make the obvious choice.

Regulatory Context
CFPB oversight under Regulation Z (12 CFR Part 1026)
State licensing: multi-state compliance obligations
NMLS-registered: originator-level attribution in audit trail
Dual obligation for correspondents: own compliance + aggregator standards
Market Pressure
Aggregators increasingly requiring evidence of AVM governance
GSE seller/servicer guides evolving to reference AVM controls
Competitive differentiation: compliance proof as a loan-sale asset
Warehouse lenders asking about AVM quality control programs
Platform Fit
Standard or Professional plan depending on volume and integration needs
Per-loan compliance receipts travel with the loan file
Originator attribution (NMLS ID) in every session
Batch tape processing for correspondent delivery validation
Nondiscrimination monitoring across the full origination portfolio
Regulatory Context
Fannie Mae Selling Guide: AVM governance and quality control requirements
Freddie Mac Seller/Servicer Guide: parallel AVM quality standards
FHFA oversight: the regulator that governs the GSEs themselves
Dual obligation: the rule + GSE contractual requirements
GSE Requirements
Documented AVM quality control policies and procedures
Vendor management: which AVMs are approved and why
Confidence thresholds: minimum standards by loan and property type
Fair lending: nondiscrimination monitoring across AVM-backed decisions
Audit trail: evidence that controls were followed for each loan delivered
Platform Fit
Professional or Enterprise plan for API and SFTP integration
MISMO-normalized confidence scoring aligns with GSE data standards
Written policy document auto-generated from live configuration
Batch processing for delivery tape validation before GSE submission
Vendor firewall: approved-only mode for GSE-sanctioned AVM vendors
Examiner package: one-click evidence bundle for FHFA examination
04GSE Seller/Servicers

The standard the GSEs will expect.

Fannie Mae and Freddie Mac seller/servicers occupy a unique position in the regulatory landscape. They must comply with the AVM Final Rule as mortgage originators — and simultaneously satisfy the GSE selling guides, which are evolving to incorporate AVM governance expectations of their own.

The FHFA, which regulates both GSEs, was one of the six agencies that issued the rule. As the GSEs update their seller/servicer requirements to reflect the new regulatory environment, institutions that already have a documented, operational control system will be ahead of every forthcoming requirement.

The platform's MISMO-normalized confidence scoring aligns directly with the data standards the GSEs already use. The written policy document — auto-generated from your live configuration — is the artifact a GSE reviewer would ask for during a seller/servicer review. It is always current because it is always derived from your actual policies, not a Word document last updated eighteen months ago.

05Secondary Market & Securitization

Loan-level proof for capital markets.

The AVM Final Rule explicitly covers secondary market issuers — any party that creates, structures, or organizes a mortgage-backed securities transaction. Private-label securitizers, aggregators acquiring loans for RMBS issuance, and servicers making collateral-dependent decisions all fall within the rule's scope.

For capital markets participants, AVM compliance is not an origination concern — it is a diligence concern. The question is not “did we follow our policies?” It is “can we prove, at the loan level, that the valuations in this pool were evaluated under a documented quality control framework?”

The platform produces exactly that proof. Process an acquisition tape through the batch API, and every loan receives a cryptographic compliance proof — MISMO-normalized confidence, five-factor policy check, nondiscrimination tags, and a hash-chain position linking it into the institution's verifiable evidence ledger. These are the artifacts that belong in a due diligence data room.

Regulatory Context
Rule covers secondary market issuers making securitization determinations
Private-label RMBS: AVM governance as a diligence requirement
Aggregator obligations: quality control over acquired loan portfolios
Servicer obligations: AVM controls for loss mitigation valuations
Capital Markets Demand
Rating agencies evaluating AVM governance in collateral analysis
Investors asking for evidence of valuation quality controls
Due diligence firms adding AVM compliance to review scope
Loan-level proof packets becoming a transaction deliverable
Platform Fit
Enterprise plan for dedicated infrastructure and high-volume processing
Batch API processes acquisition tapes at scale (10,000 loans per request)
Per-loan compliance proofs for due diligence data rooms
MISMO-normalized output integrates with existing data infrastructure
Vendor analytics across acquired portfolios: multi-vendor comparison
Nondiscrimination analysis across acquired loan pools
Operational Coverage

Ten domains. One proof layer.

Across every institution type, the platform covers the full operational surface of AVM compliance — from origination through securitization, from vendor selection through fair lending monitoring, from the first loan to the millionth.

Mortgage Origination

Policy-enforced AVM compliance at the point of origination

Valuation Governance

Institutional control over which AVMs are used, how, and by whom

AVM Quality Control

Cryptographically verifiable random sample QC with audit trail

Nondiscrimination Monitoring

Continuous disparate impact analysis across geography and demographics

AMC Operations

Vendor management, firewall controls, and multi-vendor normalization

GSE Seller/Servicer Oversight

Evidence of AVM governance for GSE compliance requirements

Securitization Diligence

Loan-level valuation proof packets for RMBS transactions

Investor Evidence

Verifiable compliance artifacts for capital markets participants

Model Risk Governance

Cross-vendor performance analytics and confidence tier monitoring

Collateral Proof

SHA-256 sealed valuation evidence for the life of the loan

One platform. Every institution.
One standard of proof.

Whether your institution manages fifty AVMs a year or fifty thousand a day, the platform produces the same cryptographic evidence, the same five-factor enforcement, and the same examiner-ready proof. Start your free trial. Your compliance evidence begins building from the first loan you process.

AVM Final Rule in effect since October 1, 2025 · FIRREA § 1125 · 12 CFR Part 1125