Tez I Solutions

Industries · Title and settlement

How we handle your customers’ data

Your CRM holds the agents who stopped sending files and the customers who closed once and never came back. Asking them again is regulated twice over — by privacy law, and by the kickback rules.

Applies to
Title agencies, title and escrow companies, settlement and closing companies
Covers
Lead reactivation and AI services
Current as of
October 2026 · V1
Book a call

Free download

Get the Title and settlement documentation as a PDF.

Tell us where to send follow-up questions, and the download starts straight away.

We use these details only to send you this document and to follow up with you about it — by email, or by phone. We won't add you to a mailing list, sell them, or share them with anyone. See our privacy policy.

Part 1

Lead reactivation

How your list is checked, ranked and worked — what leaves your side, what never does, and the rules your industry adds.

What we take, where it goes, and who sees it.

For owners, compliance and operations

Lead reactivation works the relationships your company already has — agents and loan officers who sent files and then stopped, customers who closed with you once, people who asked for a quote and never ordered. We rank them by likelihood to send or open an order and work the list from the top, so your team spends its time on the people most likely to come back.

Every one of those records is regulated. Your customers’ information is protected by the Gramm-Leach-Bliley Act, through your insurance department or the FTC, and every message is covered by federal and state telemarketing law. The agents and loan officers on the list bring a second set of rules: RESPA section 8 and your state’s anti-inducement law decide what any message to them may offer. This document sets out, control by control, how the engagement keeps your company inside those rules — and which decisions stay with you. It is written for your owner, compliance lead and counsel, and for your vendor file.

Sections 02 to 06 are the plain-English part. They show the whole system in pictures, explain the four things the ranking looks at, and follow one example lead from your CRM to your escrow officer’s desk. The sections after them are the detail your counsel will check.

01

Commitments

Ten commitments, before the detail

  • 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails, property addresses and file numbers stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
  • 02 · Nothing goes out without your approval — Your owner or compliance lead approves every template and every batch before use. Our review sits on top of yours, never in place of it.
  • 03 · Sent from your channels, recorded in your CRM — Messages go out from your own domain and numbers, and every one is logged against the record. Nothing arrives from a sender your contacts do not know.
  • 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending — for agents’ mobiles as for consumers’. Opt-outs are permanent.
  • 05 · Nothing of value offered for business — No gift, credit, discount, free service or co-marketing in any message, to an agent, a lender or a customer. Your service is the only thing on offer.
  • 06 · No money talk, ever — No wiring instructions, payment links, payoff figures or requests for account details. Any question about funds goes to your escrow officer.
  • 07 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction. Nothing passes between our clients.
  • 08 · Breach notice within 72 hours — As soon as possible and no later than 72 hours, so you can meet your own clocks: your insurance commissioner, the New York DFS or the FTC.
  • 09 · Return and destruction, certified — At the end of the engagement your data, including the identity key, is returned or destroyed, and we confirm it in writing.
  • 10 · A fee your counsel can defend — Paid for services actually performed. How each of our two fee models is treated under the kickback rules is set out in section 14.

02

The whole picture

The system on one page

The system works in three zones. Names, contact details and property addresses stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your company approves and sends.

Three zones: your company keeps identity, Tez scoring sees random IDs and facts, results return to your company YOUR COMPANY · NAMES, CONTACTS AND ADDRESSES STAY HERE G2  Check the list Opt-outs, Do Not Call, open files Swap names for IDs The key stays with you G3  Notes into facts Answers from a fixed list TEZ SCORING · RANDOM IDS AND FACTS ONLY Score and rank Four factors, plain arithmetic G4  Explain A reason and a short summary Pick the next step Channel and timing YOUR COMPANY · RESULTS LAND HERE Match back ID to your CRM record G5  Your approval Owner or compliance lead G6  Send From your own channels Outcomes (order opened, file closed) come back by random ID and improve your company’s ranking only. G1  The agreement and intake review clear before any data moves. G7  Retention and destruction.

G1 — the agreement and intake review — clears before any data moves. G7 covers retention and destruction.

Dashed gold-edged boxes, marked G1 to G7, are compliance gates. Nothing passes a gate until it clears. Section 03 lists what each one checks.

03

Step by step

From our first conversation to the first message

Seventeen steps in five phases. The gate marks show where a compliance check has to clear before the work moves on.

Onboard (before any data)

  • 01 First conversation — How your company works its relationships today
  • 02 Agreement — Roles, purpose, fee terms, 72-hour notice G1
  • 03 Intake review — Lead sources, consent wording, your states’ rules G1
  • 04 Secure environment — In your environment, or our workstation

Prepare (on your side)

  • 05 Map your stages — Your CRM statuses to eight shared stages
  • 06 Check the list — Opt-outs, Do Not Call, open files, claims G2
  • 07 Swap names for IDs — A random ID; the key stays with you
  • 08 Notes into facts — Fixed-list answers; figures become tiers G3

Rank (Tez scoring)

  • 09 Score — Intent, Opening, Reachability, Fit
  • 10 Tier and reasons — A to D, with the top reasons
  • 11 Short summary — Why call, and an opening line, checked G4
  • 12 Next step — Channel by consent, and timing

Act (on your side)

  • 13 Match back — The ranked list appears in your CRM
  • 14 Your approval — Owner or compliance lead approves G5
  • 15 Send — Re-checked at sending; from your channels G6

Learn (ongoing)

  • 16 Record outcomes — Orders opened, files closed; a held-back group
  • 17 Improve and report — Your ranking only; results you can check G7
GateWhenWhat has to be true to passWho decides
G1Before any dataSigned agreement; your lead sources, consent wording and opt-out records reviewed; your licences, states and fee model confirmed with your counselYour company and Tez
G2As the list arrivesOpt-outs, Do Not Call, open files, open claims, complaints and anyone hostile are set aside and never rankedSoftware, on your rules
G3Before anything leaves your sideOnly approved facts cross: no names, contact details, addresses, notes, exact figures or exact datesSoftware, checked by Tez
G4After a summary is draftedNo personal data, no offer of value, no money talk, nothing the facts do not supportSoftware, then your team
G5Before any outreachYour owner or compliance lead approves the wording and the batchYour company
G6At the moment of sendingConsent for that channel, Do Not Call, quiet hours in the contact’s time zone, opt-outsSoftware, on your channels
G7Throughout, and at the endOutcomes kept by random ID, used for your company only, returned or destroyed at terminationTez, certified to you

04

The ranking

How the list is put in order

Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.

Leads pass a gate, are scored on four factors, and produce an order, a reason and a next step G2  Checked first Opt-outs, Do Not Call, open files Set aside Never ranked or contacted THE FOUR FACTORS · BUILT FOR EVERY LEAD Intent How far they got, and how recently Opening Why they paused, and what has changed Reachability Can we reach them, with consent Fit Can your company still serve them Score and rank Plain arithmetic, no AI model Value tier Optional, your call Order and tier A to D, best first Why this lead Top reasons, in one line Next step Channel, timing, angle
FactorThe question it answersWhat it looks at, for a title company
IntentHow strong was the relationship, and how long ago?Customers: quote requested, order opened, file closed. Agents and loan officers: how many files they sent, and when the last one closed. Whether they replied before.
OpeningIs there a real reason to get back in touch?Why they paused: a move, a slow market, a lender’s choice of provider, a service problem. A condition they named, and whether it has passed.
ReachabilityCan we reach them, and are we allowed to?A working email or phone. Consent on file for each channel. Do Not Call status, and the time since their last closing or quote.
FitCan your company still serve them?A county or state you are licensed in. A transaction type you handle. Whether they still work in your market, from your own records.

How the ranking gets better

  • 01It starts from your team’s experience — Your escrow officers and sales team tell us how often each kind of paused contact comes back. Those estimates set the first odds, and we call them estimates until your results come in.
  • 02It corrects itself from your results — As orders are opened, closed or declined, the odds for each reason move toward what actually happened at your company.
  • 03It becomes a model of your company alone — After about 300 recorded outcomes, the ranking is fitted to your company’s results. It is never trained on, or pooled with, another company’s data.
  • 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back for a set period. Comparing the two groups shows what the outreach changed, rather than what would have happened anyway.

05

A worked example

One lead, from your CRM to your escrow officer

Dana Whitfield is fictional: a real estate agent who used to send files and then stopped. Her record is shaped like a real one. Follow it through the four cards, left to right and top to bottom.

1 · Your CRM record (stays with you)

FieldValueNote
nameDana Whitfieldkey table
phone(281) 555-0163key table
emaildana.w@example.comkey table
CRM ID0038f00000Lm4key table
typeReferral partner, agentbecomes a stage
noteMoved to Lakeside Realty in May; says the new office mostly uses another title companybecomes facts
files sent6 in 2025becomes a tier
last closingJanuary 22, 2026becomes days

2 · What we receive (leaves your side)

FieldValueNote
IDr_4Hc8pW1zrandom
stagePast referral partnerIntent
days since257Intent
reasonChanged officeOpening
issueNone recordedOpening
reachEmail yes · text no consentReachability
fitWorks in your counties yesFit
value tier2 of 3, only if you opt inoptional

Never leaves your side: her name, phone, email, CRM ID, the note itself, the brokerage name, the file count, exact dates.

3 · What comes back (back to you)

FieldValueNote
IDr_4Hc8pW1z
score64 · tier B
reasons+ sent files before · + paused for a move, not service · − 257 days since last file
reason linePast referral partner; paused after an office change, not a service problem.fixed wording
summaryShe sent files regularly until she changed offices. Nothing points to a problem with your service. A good opener is to ask how the new office is going and offer your team on her next closing.AI, checked
next stepEmail from her former escrow officer, Wednesday morning

4 · In your CRM (stays with you)

FieldValueNote
recordDana Whitfield · tier B · 64matched back
fieldsReason line, summary and next step added to her record
draft“Hi {first_name}, …” with her name filled in only at sendingplaceholder
flagsText blocked, no consent · nothing of value offeredG4 G6

No text consent on file, so the next step is email. The draft offers your service and nothing else — no lunch, credit or marketing help — because she is a referral source. Her escrow officer sees her name here, in your own CRM, for the first time.

  • 01Her note became a few facts — “Moved to Lakeside Realty” left only as “changed office.” The brokerage name, and what she said about its title company, never left your side. Had the lead been a past buyer, the property address would have stayed in the key table in the same way.

06

The suggestion

How the “why call” note is written and checked

Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. The AI writes; it does not decide. The order comes from arithmetic, and your company approves anything sent.

Facts feed a fixed-wording reason line and an AI draft; both pass a check before your team sees them, then approval and sending The facts and reasons Random ID, no names or figures Your rules Script, never-say list Reason line Fixed wording, filled from the facts AI draft Short summary and an opening line G4  Checked before anyone sees it Personal data, offers of value, money talk Passes Goes to your team, in your CRM Fails Reason line only, flagged for review G5 + G6  Approve, then send Your sign-off; checks at sending

The four checks at gate G4, on top of your never-say list

  • No personal data — The draft may not contain a name, number, email or address. Names appear only as a placeholder, filled in on your side at sending.
  • Nothing of value offered — No gift, meal, credit, discount, free service, co-marketing or reward for referring others. The draft offers your service, nothing more (section 12).
  • No money talk — No wiring instructions, payment links, payoffs, account details, rate quotes or promises about price or timing.
  • Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.

07

Roles

Your company stays the financial institution

Under the Gramm-Leach-Bliley Act your company is a financial institution and Tez I Solutions is your service provider. A title agency or insurer shares customer information with us under its state’s insurance privacy rule, modelled on NAIC Model 672; an escrow or settlement company under Regulation P (12 CFR 1016.13), which expressly covers marketing your own services. Either way the contract limits our use to this engagement, and the reuse limits then bind us. Your security rule — the FTC Safeguards Rule, your state’s version of NAIC Model 668, or NYDFS Part 500 — requires you to choose and oversee us. This is how responsibility divides.

ObligationYour companyTez I Solutions
Privacy notices and opt-outsOwnsHonours your suppression and opt-out lists
Approval of communicationsOwner or compliance lead approves before useSubmits templates; never alters approved wording
Referral-source rulesOwns, with your counselDrafts that offer nothing of value; flags anything that might
Records of outreachOwns your CRMLogs every message against the record
How leads were obtainedWarrants it in the agreementRecords the consent source and enforces it at send time
Security of data we holdOverseesOperates the controls in sections 10 and 11
Notice to regulators and customersOwns: commissioner, DFS or FTC, and state breach lawsNotifies you within 72 hours and supports the investigation
Vendor due diligencePerforms and documentsCompletes questionnaires and supplies evidence
Access and deletion requestsReceives and instructsExecutes within your deadline and confirms
Return or destructionInstructsExecutes and certifies in writing

08

Data

What we take, and what we never take

The least data that lets the list be ranked and worked. Where a figure matters, we keep a tier.

DataHow it is handledReaches the AI model
Name, phone, email, mailing addressHeld only in the encrypted key table on your side; used to address a message when it is sent.No
Property address, parcel and file numbersKept in the key table: land records tie a property to its owner. Only the county is used, for Fit.County only
SSN, birth date, loan and bank numbers, wiringExcluded from the export; if one appears in a note, the record is quarantined.No
Sale price, loan amount, premium, file countOnly if you agree: a three-level tier made on your side. The figure never leaves.No
Quote, order and closing datesConverted to intervals — “257 days since last closing.”Interval only
Lead type, stage, source, assigned officerKept as categories; staff, brokerage and lender names replaced with codes.As categories
Call and relationship notesRead on your side and turned into fixed-list answers (section 09). The note itself never leaves.Fixed-list answers only
Consent records and opt-outsKept as an append-only history and enforced at send time.No
Commitments, closing and payoff documents, claims filesNot requested, not used to rank, not sent.No

09

The privacy layer

Where AI sits, and what it sees

StationWhat happensHolds or sees
01 · Your company — Your CRMFull records stay here. Only the agreed fields are read.Holds: everything, as today
02 · Secure env. — Separation, and notes into factsA local model with no outside connection answers fixed questions about each note. The key lives only here.Holds: identifiers, key table, notes
03 · Tez scoring — Ranking, then a short summaryRanking is arithmetic in our own code. Anthropic’s Claude words a summary from the facts.Sees: random ID, fixed-list facts
04 · Your channels — Approved, then sentNames filled in on your side; consent checked; sent from your domain and numbers.Holds: the message, in your CRM

Notes are the most sensitive part of a record and the most useful. So they are read where they already are, and only short answers leave. Five layers make sure of it, following NIST’s de-identification guidance.

LayerWhat it does
1 · Field allow-listOnly approved columns are read. Structured identifiers are separated by rule, not by a model’s judgement.
2 · Identifiers stripped firstPhone numbers, emails, street addresses, file, policy, loan and account numbers, Social Security numbers, dollar amounts and dates are removed before the local model reads a note.
3 · Fixed questions, fixed answersThe local model answers set questions — why they paused, whether a service problem is recorded, whether they named a condition — by choosing from a list your compliance lead has seen. It cannot write free text.
4 · Unsure means a person decidesAn answer the model is not confident about is not guessed. The record is held for a person to review. The process fails closed.
5 · Final scanEvery record is scanned again before it leaves. A record carrying anything outside the approved fields is held back, not sent.

10

Where it runs

Two ways to run the secure environment

The secure environment is where identifiable data lives during the engagement, and your company chooses where it sits. In both options the key table never leaves it, and the AI provider receives only a random ID and fixed-list facts.

Inside your environmentOn a Tez-operated workstation
Where raw data sitsYour infrastructure; it never leaves your perimeterAn encrypted workstation operated by Tez, in a separate encrypted volume per company
AccessYou control it. We use a named, least-privilege account you can revoke at any timeOne named individual, background-checked, with multi-factor authentication
NetworkYour controlsOutbound limited to the AI provider and your sending channels
LoggingYour logging stackAccess log kept for the engagement, provided on request
SuitsCompanies with an IT team or managed IT providerCompanies without capacity to host it

Workstation standard, when Tez operates it

  • Encrypted at rest — Full-disk encryption, as Massachusetts 201 CMR 17.00 requires for laptops, plus a separate encrypted volume for each company’s data.
  • Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
  • No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
  • Wiped at the end — The company’s volume is destroyed at termination and the destruction certified in writing.

11

Security and incidents

The controls, and what happens if one fails

ControlEvidence you can ask for
Written information security program, modelled on Massachusetts 201 CMR 17.00, the New York SHIELD Act and ALTA Best Practices Pillar 3The program document
Encryption in transit and at restConfiguration record
Multi-factor authentication on every account that touches your dataAccount inventory
Access limited to named individuals, logged and reviewed quarterlyAccess list, review log, log extract
Background check for anyone with access, on your requestWritten confirmation
Raw data held only for the life of the engagementRetention schedule
Return or destruction within 30 days of terminationSigned certificate
Cyber liability insurance, where your contract requires itCertificate of insurance
Written incident response plan, reviewed each yearThe plan and its last review

If something goes wrong

  • 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
  • 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. Updates follow as we investigate.
  • 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation.
  • 04 · Support your notice, never pre-empt it — Your clocks run from our notice: 72 hours to your commissioner (Model 668) or the DFS (Part 500), 30 days to the FTC. Notice is your decision; we never contact your customers about it.

12

Referral rules

Nothing of value, to anyone, for business

Reactivating an agent or loan officer is asking a referral source for business — the conduct RESPA section 8 and the state title laws police. The rails below are built into gate G4.

  • 01RESPA section 8 — your service is the only offer — No fee, kickback or thing of value for referring settlement business on a federally related loan, and Regulation X reads the term broadly — free services, paid expenses, discounts, credits. So a message to an agent or lender offers turn times, a named contact and an invitation to send the next file. Events and education, which may not be tied to referrals or cover the agent’s costs, stay with you and your counsel.
  • 02State law is stricter, and needs no loan — Texas bars any thing of value for soliciting or referring title business; California and Colorado bar inducements for placing it; Washington allows only what its rules list; New York’s ban covers keeping existing business. Your counsel names your states at G1, and the strictest rule applies.
  • 03Customers: no referral rewards, no unfiled discounts — No reward for referring friends. No rebate or discount outside your filed or promulgated rates. Nothing suggesting a past seller require a buyer to use your company (RESPA section 9).
  • 04No money talk — the wire-fraud rail — No wiring instructions, payoffs, account numbers or payment links, ever. A reply about funds goes to your escrow officer, who verifies by a number on file, as ALTA Pillar 2 expects. Open files are set aside at G2, so nothing lands mid-closing.
  • 05Your company only, and nothing between clients — We write for your company about your services. No message has one affiliate refer a consumer to another; those disclosures stay with you. If we also serve a brokerage or lender in your market, nothing passes between the engagements.

13

Consent

No evidenced consent, no text message

Under the Telephone Consumer Protection Act the party that sends a message can be liable for it directly. So consent is enforced in software at the moment of sending, not left to policy — and an agent’s mobile number gets the same treatment as a customer’s. Recent rulings narrowed the autodialer definition and freed courts from the FCC’s readings; neither changes what we do.

  • 01 · A consent history, not a checkbox — Each lead’s consent is an append-only record of source, wording, channel and date. Contactability is derived from it, never overwritten.
  • 02 · Checked when the message sends — Consent, suppression, Do Not Call and quiet hours are rechecked at sending, not at list-building. Yesterday’s opt-out holds today.
  • 03 · Aged leads without evidenced consent — Email, or your team calling directly — not text. For Do Not Call, a closed file supports calls for 18 months and a quote request for three; neither replaces consent for automated texts.
  • 04 · Do Not Call and reassigned numbers — Checked against the National Do Not Call Registry and the FCC Reassigned Numbers Database. Results dated and stored.
  • 05 · Quiet hours and state law — 8am to 9pm in the contact’s local time, narrower where required. Florida, Oklahoma, Maryland, Washington and Texas SB 140 rules applied by state.
  • 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your staff is honoured on every channel and survives any re-import — stricter than the FCC’s 2026 order. Email within 10 business days.

14

How we are paid

Two fee models, and how each is treated

We offer two models. Fees are set in conversation and are not in this document. What belongs here is how each model is treated under the kickback and anti-inducement rules, so your counsel can choose with that in view. Regulators judge marketing agreements on their facts; none is presumed lawful.

Model A: Flat monthly fee

A fixed fee for operating the service. It does not depend on orders opened, files closed or premium written.

  • RESPA. Section 8(c)(2) permits a bona fide payment for services actually performed. It must bear a reasonable relationship to the market value of the work, with the value of any business that follows left out (Regulation X 1024.14(g)(2)).
  • State law. Texas, for example, lets a title company buy advertising at market rates. A fixed fee for defined work fits that pattern.
  • Never adjusted on results. The agreement and invoices show what the fee paid for.

Model B: Results-based fee

A share of revenue from files attributed to reactivated contacts, measured from your CRM’s own records.

  • RESPA. A payment tied to the volume or value of business is evidence of an agreement to pay for referrals (1024.14(e)). The exception for paying your own employees (1024.14(g)(1)(vii)) does not reach an outside vendor.
  • State law. Texas bars anyone receiving a thing of value, a portion of premium included, for soliciting title business; Washington bars rewarding anyone for causing it. California and New York aim at the parties and their agents, so counsel reads each state. These rules reach cash deals too.
  • Offered only where your counsel approves the structure in writing. We expect most title companies to rule it out.

15

Subprocessors and contract

Who else touches the data, and what we sign

SubprocessorWhat it holdsWhen
Anthropic (Claude API)A random ID and fixed-list facts only. No names, contact details, addresses, notes or exact figures. Not used for training by default under Anthropic’s commercial terms; zero data retention requested where offered; can run through your own cloud provider insteadEvery engagement
Your email, texting and CRM providersMessages and records, as they do todayEvery engagement, under your contracts
Messaging provider operated by TezPhone numbers and message contentOnly if you have no texting channel of your own; numbers registered to your company, every message logged to your CRM
Operator console hostingNamed in your agreement, with what it holdsWhere your team uses our console

The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor.

What the agreement contains

  • Roles and purpose — Your company as financial institution, Tez as service provider; use limited to this engagement, as Regulation P 1016.13 and the insurance privacy rules require.
  • No secondary use — No training, no sale, no enrichment without written instruction. No lead, list or contact passes to any other client.
  • Security exhibit and 72-hour notice — The controls in sections 09 to 11, as binding terms.
  • Fee terms — The work the fee pays for, in writing, with no payment to or from any referral source.
  • Consent warranty — Your company’s representation of how the leads were obtained.
  • Privacy requests, audit and exit — Access and deletion within your deadlines, including state privacy laws; audit and questionnaire rights; return or certified destruction at termination.

16

Regulatory map

Each rule, and where it is addressed

RuleWhat it requires hereSection
RESPA section 8, Regulation X 1024.14No thing of value for referrals; payment only for services actually performed12 14
RESPA section 8(c)(4), Regulation X 1024.15Affiliated business arrangements and their disclosure12
RESPA section 9No seller-required title company12
State title anti-inducement lawsNothing of value to producers; no rebates or unfiled discounts; no pay for placing business06 12 14
Regulation P 1016.11 and 1016.13; NAIC Model 672Service-provider exception; use limited to the engagement07 15
FTC Safeguards Rule, 16 CFR 314Safeguards, service-provider oversight, 30-day FTC notice07 11
NAIC Model 668; NYDFS Part 500Security program, vendor oversight, 72-hour notice07 11
ALTA Best Practices 4.2, Pillars 2 and 3Wire procedures; security plan, background checks, service providers11 12
TCPA and the Do Not Call rulesConsent, revocation, Do Not Call, quiet hours13
State telemarketing lawsState consent and calling-hours rules13
CAN-SPAMUnsubscribe, address, accurate headers13
Massachusetts 201 CMR 17.00, New York SHIELD ActWritten security program, encryption10 11
State comprehensive privacy lawsAccess, deletion, no sale, for data outside the GLBA exemption08 15
Fair Housing ActProtected characteristics never used to rank04
NIST IR 8053, SP 800-188De-identification practice08 09

17

References

Every requirement, traced to its source

Each commitment in this document rests on a primary source: a statute, a regulation, a regulator’s own guidance, a court decision or the industry’s own standard. They are listed here so your counsel can check our reading against the text. Links were current in October 2026.

Settlement and referral rulesRelied on forSections
RESPA section 8, 12 U.S.C. 2607 (law.cornell.edu/uscode/text/12/2607)Ban on things of value for referrals; payment for services actually performed; affiliated business; penalties and state enforcement12 14
RESPA section 9, 12 U.S.C. 2608 (law.cornell.edu/uscode/text/12/2608)A seller may not require a particular title company12
Regulation X, 12 CFR 1024.14 (ecfr.gov/current/title-12/chapter-X/part-1024/subpart-B/section-1024.14)Thing of value; referral; volume-linked payment as evidence; employee exception; market value12 14
Regulation X, 12 CFR 1024.15 (ecfr.gov/current/title-12/chapter-X/part-1024/subpart-B/section-1024.15)Affiliated business arrangements12
CFPB, RESPA Section 8 FAQs, October 2020 (consumerfinance.gov/compliance/compliance-resources/mortgage-resources/real-estate-settlement-procedures-act/real-estate-settlement-procedures-act-faqs/)Gifts and promotional activity; marketing versus referral; payments under marketing agreements12 14
CFPB, rescission of Compliance Bulletin 2015-05, October 7, 2020 (consumerfinance.gov/compliance/supervisory-guidance/bulletin-respa-compliance-marketing-services-agreements/)Marketing agreements are not presumed lawful; review is fact-specific14
PHH Corp. v. CFPB, 839 F.3d 1 (D.C. Cir. 2016); statutory holding reinstated en banc, 881 F.3d 75 (D.C. Cir. 2018)Reasonable payment for services actually performed under section 8(c)14
Fair Housing Act, 42 U.S.C. 3604 (law.cornell.edu/uscode/text/42/3604)The protected characteristics the ranking never uses04
State title rulesRelied on forSections
Texas Insurance Code ch. 2502, incl. 2502.051 to 2502.055 (statutes.capitol.texas.gov/Docs/IN/htm/IN.2502.htm)No thing of value for soliciting or referring title business; advertising at market rates12 14
California Insurance Code 12404 (leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=INS&sectionNum=12404.)No consideration to the parties or their agents as an inducement for placing or referring title business; no paid meals or advertising for them12 14
Colorado C.R.S. 10-11-108; 3 CCR 702-8, Regulation 8-1-3Unlawful inducements, incl. producing marketing for a settlement producer12
New York Insurance Law 6409(d); Insurance Regulation 208, 11 NYCRR 228; DFS Circular Letter 2a (2019) (dfs.ny.gov/industry_guidance/circular_letters/cl2019_02a)Inducements to applicants and their agents barred, for future and existing business; upheld on appeal12 14
Washington RCW 48.29.210; WAC 284-29-200 to 284-29-265 (app.leg.wa.gov/rcw/default.aspx?cite=48.29.210)Only listed things of value permitted; no advertising with a producer; no reward for causing business12 14
Privacy and data securityRelied on forSections
Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 (law.cornell.edu/uscode/text/15/chapter-94)The federal basis for protecting consumers’ nonpublic personal information07 08
Regulation P, 12 CFR Part 1016 (ecfr.gov/current/title-12/chapter-X/part-1016)Service-provider exception, incl. marketing your own services (1016.13); reuse limits (1016.11)07 15
FTC Safeguards Rule, 16 CFR Part 314 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314)Settlement services as a financial institution (314.2); service-provider oversight (314.4(f)); FTC notice (314.4(j))07 11
NAIC Privacy of Consumer Financial and Health Information Regulation, Model 672 (content.naic.org/sites/default/files/model-law-672.pdf)Insurance privacy: service-provider exception and reuse limits, as adopted by each state07 15
NAIC Insurance Data Security Model Law, Model 668 (content.naic.org/sites/default/files/model-law-668.pdf)Security program, third-party service provider oversight, 72-hour notice to the commissioner01 07 11
NYDFS Cybersecurity Regulation, 23 NYCRR Part 500 (dfs.ny.gov/cybersecurity/requirements)Third-party service provider policy (500.11) and 72-hour notice (500.17), small licensees included01 07 11
ALTA Title Insurance and Settlement Company Best Practices, Version 4.2, August 2025 (alta.org/policies-and-standards/best-practices/)Pillar 2 wire procedures; Pillar 3 security plan, background checks, service providers11 12
Massachusetts 201 CMR 17.00 (mass.gov/regulations/201-CMR-1700-standards-for-the-protection-of-personal-information-of-ma-residents)Written security program, encryption on laptops and in transit, service-provider contracts10 11
New York SHIELD Act, N.Y. Gen. Bus. Law 899-aa and 899-bbReasonable safeguards and breach notice for New York residents’ data11
California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq., incl. 1798.145(e)Data-level GLBA exemption; duties for data outside it, such as agents’ records08 15
State privacy law amendments narrowing GLBA exemptions: Oregon, Minnesota, Montana (Oct 2025), Connecticut (Jul 2026)Why privacy-request handling covers more than GLBA data15
Telemarketing and emailRelied on forSections
Telephone Consumer Protection Act, 47 U.S.C. 227 (law.cornell.edu/uscode/text/47/227)Consent for marketing texts and calls; statutory damages; sender liability13
FCC rules, 47 CFR 64.1200Prior express written consent, Do Not Call, quiet hours, revocation of consent13
FCC Report and Order on revocation of consent, adopted September 30, 2026A telemarketing opt-out revokes all telemarketing; effective 30 days after publication13 18
Telemarketing Sales Rule, 16 CFR Part 310Established business relationship: 18 months after a transaction, 3 months after an inquiry13
National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us)The two checks run before any number is contacted13
Facebook, Inc. v. Duguid, 592 U.S. 395 (2021); McLaughlin Chiropractic Associates v. McKesson Corp. (U.S. Supreme Court, June 2025)Scope of the autodialer definition; courts not bound by FCC interpretations13
Florida Telephone Solicitation Act, Fla. Stat. 501.059; Texas SB 140 (2025), Tex. Bus. & Com. Code ch. 302State rules that treat texts as solicitation, applied by the contact’s state13
CAN-SPAM Act, 15 U.S.C. 7701 et seq.; FTC compliance guide (ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business)Unsubscribe within 10 business days, physical address, accurate headers13
De-identification and AIRelied on forSections
NIST IR 8053, De-Identification of Personal Information, 2015 (nvlpubs.nist.gov/nistpubs/ir/2015/NIST.IR.8053.pdf)Quasi-identifiers, re-identification risk, why pseudonymization is reversible08 09
NIST SP 800-188, De-Identifying Government Datasets, 2023 (csrc.nist.gov/pubs/sp/800/188/final)Generalization of figures into bands; de-identification as risk reduction08 09
NIST SP 800-122, Guide to Protecting the Confidentiality of PII, 2010 (csrc.nist.gov/pubs/sp/800/122/final)Classifying which fields are identifying and how sensitive each is08
Anthropic, Commercial Terms of Service (anthropic.com/legal/commercial-terms)No training on commercial API inputs and outputs by default09 15

18

Limits

What this document is not

  • 01Not legal advice — Your counsel and compliance lead decide how these rules apply to your company, in your states. This document tells them what we do so they can.
  • 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We complete your vendor questionnaire, and your underwriter’s or lender’s, and provide the policies and evidence behind each control instead.
  • 03Not a title, escrow or settlement provider — Tez I Solutions is not a title insurance agent or escrow agent. We do not examine title, quote premiums, take escrow instructions or handle funds, and we refer no one to anyone.
  • 04Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s consent revocation order of September 2026 among them. We review this document at least once a year and whenever a rule it relies on changes.
  • 05Not a promise of results — A score says which contacts to approach first, not who will send or open an order. Until your company’s own outcomes are recorded, the odds behind it are estimates drawn from your team’s experience.

Part 2

AI services

How we handle your data inside your AI tools.

AI services puts a standing AI engineer across the AI tools your business already pays for — ChatGPT, Claude, Copilot, Gemini and the AI inside the software you use. We connect those tools to your CRM, inbox, calendar and files, build the workflows that do the repeat work, set up your processes and brand voice inside them, train your team, and look after the accounts. The tools stay yours, under your own contracts with each vendor. That changes how data protection works. In lead reactivation we keep names and contact details away from the AI provider by design. Here, a tool connected to your CRM will see the records it needs to do its job, names included. So the protections in this document are about something else: whose account it is, what each connection can reach, what the vendor's terms allow, who approves a workflow before it goes live, and how our access ends. Sections A1 to A6 are the same for every business we work with. Your industry's page adds sections A7 and A8: what your industry's rules mean for your AI tools, and where those rules come from.

A1

Commitments

Ten commitments, before the detail

  • 01 · Your accounts, on business terms — We work only in accounts your business owns, on business plans. Never in a personal or consumer account — ours, yours or an employee's.
  • 02 · A named user, never a shared password — You add us as a named user with our own sign-in and multi-factor authentication. We never ask for a shared password, and you should never send one to us by email.
  • 03 · The least access that does the job — Each connection reaches only the data its workflow needs. Admin rights are used for set-up tasks, logged, and reduced afterwards.
  • 04 · Nothing goes live without your approval — Every connection, workflow and set of instructions is approved by you, in writing, before it is switched on. So is every change to one that is already running.
  • 05 · Automated where it is routine, a person in the loop where it is not — Routine, rule-based work can run on its own once you have approved it: sorting and tagging, summaries for your team, filing, and fixed-wording notices such as an appointment reminder from a template you signed off. Anything that needs a decision or a judgement — a reply written for a particular customer, a price, a term, a commitment, or anything your industry's page marks for review — has a person on your side in the loop before it goes anywhere. Each workflow's data sheet (A3) states which kind it is. Where your industry's page requires a person to review every customer message, that rule applies instead.
  • 06 · Your data stays in your tools — We build and test inside your workspace. We do not copy your business data into Tez's own AI accounts. Where we need examples outside your tools, we use made-up records.
  • 07 · Your data serves your business only — No reuse across clients, no sale, no training of anything by us. Prompts, instructions and workflows built from your material are yours and are not reused for anyone else.
  • 08 · Vendor data settings confirmed in writing — During onboarding we read each tool's current data terms, set its controls with you, and give you a written record. We re-check it whenever a vendor changes its terms.
  • 09 · Incident notice within 72 hours — As soon as possible and no later than 72 hours, or sooner where your industry's page says so.
  • 10 · Access removed, everything handed over — At the end, our access is removed, every credential we created is revoked or rotated, and every workflow is documented and handed over. We confirm it in writing within 30 days.

Evidence on request: every control in this document has a record you can inspect, listed in section A5. If you send us a security questionnaire, we complete it during onboarding.

A2

Accounts and access

Whose accounts, and how we get in

The AI tools, the systems they connect to and the accounts that run them all belong to your business. We are given access to them; we never hold them. That is what makes the work portable: if we part ways, everything keeps running and nothing has to be moved out of our name.

Nothing in this section starts before you have decided to work with us. The first session is a conversation. We do not ask for logins, exports or files beforehand.

Who owns what

ItemWho owns itHow we handle it
AI subscriptions and workspacesYour business — in its name, on its payment methodWe administer them for you. If a new tool would genuinely pay for itself, we say so and why, and it goes on your account, not ours.
The owner or super-admin roleYour business keeps it, with at least one person on your side who is not usWe take the lowest role that does the work. Admin rights for a set-up task are logged and reduced when the task is done.
Our sign-inA named user for each Tez person, in your directory or invited as a guestMulti-factor authentication on. No shared logins. Never a password by email, text or chat.
Connections — API keys, app authorisations, service accountsCreated in your accounts, owned by youEach one is named, listed in the access record (A5), scoped to its workflow, and stored where you control it — never pasted into a document or a message.
Personal and consumer AI accountsTheir ownersNot used for business work. If the audit finds business work in personal accounts, we tell you and recommend moving it to business seats. We never connect your systems to a personal account.

How access is set up

  • 01 · You decide what we need — We list the systems and the role each one needs, and why. You agree or strike items out.
  • 02 · You add us — Usually by adding us as a user, on a call where we walk through it together. A password is never sent.
  • 03 · We confirm the safeguards — Multi-factor authentication on, role as agreed, sign-in recorded in the access record.
  • 04 · Reviewed every quarter — We go through the access record with you and remove anything no longer needed.
  • 05 · Removed at the end — Section A5 sets out how access ends.

Roles

ObligationYour businessTez I Solutions
Contracts with AI vendorsHolds them; the vendor processes your data under themReads the data terms and records them for you (A4)
Who on your team uses which toolDecidesSets up the seats and permissions you decide
Approval of workflows and changesApproves before anything goes liveProposes, documents and builds; never switches on without approval
Review of customer-facing outputYour people review before sendingBuilds the review step into the workflow
Industry rules — licensing, records, supervision, privacy noticesOwns themBuilds to them as set out on your industry's page (A7)
Security of the access we holdOverseesOperates the controls in A5
Notice to customers or regulators after an incidentDecidesTells you within 72 hours and supports the investigation
Privacy requests from your customersReceives and instructsHelps find and remove the data in the tools we set up, within your deadline

Where a state privacy law reaches your business, we act as your service provider or processor for the access we hold, and the agreement says so.

A3

What the tools can see

Connections, scopes, and what stays out

An AI tool connected to one of your systems can see whatever that connection lets it see. An assistant that searches your files can surface anything the person using it is allowed to open — Microsoft says of its own Copilot that it "only surfaces organizational data to which individual users have at least view permissions." So the work starts with permissions, not prompts.

Before anything is connected

  • Who can see what — Before an assistant is pointed at a shared drive, inbox or CRM, we review who can open what. Folders that are open to everyone but should not be are fixed first, with your approval.
  • One data sheet per workflow — Every workflow gets a written sheet: what it reads, what it writes, who sees the result, and where a person reviews it. You approve the sheet before we build.
  • Add-ons are vendors too — A plug-in, connector, custom GPT or agent from a third party is another company handling your data. None is installed without your approval and a record of its data terms.

What a data sheet looks like

Illustration — not real client data.

WorkflowReadsWritesWho sees the resultHuman in the loop
Morning summary of new inquiriesCRM records created in the last 24 hours: name, source, service asked about, notesOne summary in the office manager's inboxOffice managerRead before anyone acts on it
First-draft reply to a quote requestThe single inquiry being answered; your approved reply templates and brand voiceA draft in the shared inbox — never sentThe person replyingEdited and sent by a person
Meeting notes to CRMThe transcript of a meeting the attendees agreed to recordA note on the matching CRM recordThe account ownerChecked before it is saved

What stays out by default

Unless your written decision says otherwise, after we have shown you what the vendor's terms and your industry's rules say, these are kept out of every prompt, instruction file and connection:

  • Social Security numbers, tax IDs, driver's licence and other government ID numbers
  • Full bank account and card numbers
  • Passwords, access codes, gate, door and alarm codes
  • Health information
  • Anything your industry's page (A7) marks as restricted

Where a connection would expose one of these — a folder of scanned IDs, a CRM field holding card numbers — the connection is narrowed to leave it out, or not built.

Before a workflow goes live

CheckWhat has to be true
Data sheetApproved by you, in writing
AccessThe connection reaches only what the sheet lists
TestRun on made-up records, or on a small set of real ones you choose, with the results shown to you
Human in the loopMarked on the data sheet. In place wherever a decision or judgement is involved: a reply written for a particular customer, a price or a term, or anything your industry's page marks for review. Routine, rule-based steps you have approved may run without one
OwnerA named person on your side who can pause it
DocumentationWritten up and stored where you keep it

AI tools make mistakes. Every workflow is built on the assumption that a draft can be wrong, which is why the review step is part of the design rather than a suggestion.

A4

Model providers and training

What the vendors do with your data, and how we check

When your team or a workflow uses ChatGPT, Claude, Copilot or Gemini, the vendor processes that data under its contract with your business. Tez is not a reseller or partner of any AI vendor, and not a party to those contracts. Whether a vendor trains its models on your data, how long it keeps prompts, whether its staff can review them, and where it processes them are set by the vendor's terms and by the plan you are on. Those terms change. So we do not promise what a vendor will do. We promise what we will do.

What we do

  • 01 · List every tool — Each AI tool and AI feature you pay for, the plan it is on, and who holds a seat.
  • 02 · Read the current terms — For each one we record what the vendor says about training on your data, retention, human review, where data is processed, and which admin controls exist. Each entry carries the date and the address of the page we read.
  • 03 · Set the controls with you — Where a tool offers a choice — training opt-outs, retention periods, chat history, which add-ons are allowed — we recommend the most protective setting that still does what you need, and you decide.
  • 04 · Give you the record — The settings record is yours, in writing. Your compliance contact can file it with your vendor reviews.
  • 05 · Re-check when terms change — When a vendor changes its data terms, we re-read them, update the record and tell you if anything moved. We also re-check the whole record at least every six months.

What the main vendors said when we checked

Read on each vendor's own page on 6 October 2026. This is the vendor's statement to its customers, not a commitment by Tez. If it changes, the vendor's current terms govern, and we update your record.

VendorWhat its page saidWhere
Anthropic — Claude, under its Commercial Terms"Anthropic may not train models on Customer Content from Services." The Commercial Terms cover Anthropic's API and the business offerings that reference them, not its consumer plans. Effective June 17, 2025.anthropic.com/legal/commercial-terms
OpenAI — APIData sent to the API is not used to train or improve OpenAI's models unless you opt in, as of March 1, 2023. Abuse-monitoring logs are kept for up to 30 days by default.developers.openai.com/api/docs/guides/your-data
OpenAI — ChatGPT business plansRead during onboarding against OpenAI's published terms for your plan, and recorded the same way.openai.com/enterprise-privacy
Microsoft — Copilot"Prompts, responses, and data accessed through Microsoft Graph aren't used to train foundation LLMs." Copilot only surfaces data a user already has permission to view.learn.microsoft.com/en-us/microsoft-365/copilot/microsoft-365-copilot-privacy
Google — Gemini in Google WorkspaceYour content "is not human reviewed or otherwise used for Generative AI model training outside your domain without permission."knowledge.workspace.google.com/admin/gemini/generative-ai-in-google-workspace-privacy-hub
AI inside your other softwareEach vendor's own terms — your CRM, phone system or accounting software. Recorded the same way during onboarding.Each vendor's data or AI terms page

Consumer plans and personal accounts

Consumer plans run on different terms from business plans — Anthropic's Commercial Terms, for one, state that they do not cover its consumer offerings. We do not do business work in consumer or personal accounts, and we do not rely on a consumer plan's settings to protect business data.

Our own tools

We use AI tools of our own to write code and documentation. Your business data does not go into them. Anything we build for you is built and tested in your workspace, or against made-up records.

A5

Records, security and incidents

What we keep, how it is protected, and what happens if something fails

Records you can inspect

Records describe what we built and changed. They live in a location your business owns, and they do not contain your customers' data.

RecordWhat it holds
Access recordEvery Tez sign-in and every connection we created: system, role or scope, date added, date reviewed, date removed
Settings recordEach tool's plan, data terms as read on a given date, and the controls set (A4)
Workflow registerEvery live workflow, with its approved data sheet (A3), its owner on your side and its documentation
Change logEvery change to a live workflow or connection: what changed, why, when, who approved it
Training recordWho was trained, on which tools and processes, and when

Changes to something already running

Every change to a live workflow is described, approved by you, tested, logged and reversible — the previous version is kept. If a vendor update breaks a workflow, or a workflow starts doing something it should not, we may pause it at once to stop harm, and tell you the same day. We do not change what a workflow does without your approval.

Security controls

ControlEvidence you can ask for
Written information security program, modelled on Massachusetts 201 CMR 17.00The program document
Multi-factor authentication on every account we use to reach your systemsAccess record
Access limited to named individuals, reviewed with you quarterlyAccess record and review log
Tez devices: full-disk encryption, screen lock, current patches, endpoint protectionConfiguration record
Your data is not stored on Tez devices or in our cloud storage; where a task needs a file locally, it is deleted when the task endsWritten procedure
Background check for anyone with access, on your requestWritten confirmation
Cyber liability insurance, where your contract requires itCertificate of insurance
Written incident response plan, reviewed each yearThe plan and its last review

If something goes wrong

An incident includes a workflow sending or showing data to the wrong person, a connection reaching more than its sheet allows, a suspected compromise of a Tez sign-in, and a vendor incident we learn of that affects your workspace.

  • 01 · Contain — Pause the workflow, revoke the affected credential or connection, and stop the exposure.
  • 02 · Notify you within 72 hours at the latest — Which systems and data, what window, what we have done. Sooner where your industry's page sets a shorter time. Updates follow as we investigate.
  • 03 · Preserve evidence — Logs, the change log and the vendor's audit records are kept intact for your investigation.
  • 04 · Support your notice, never pre-empt it — Whether customers or regulators are told is your decision. We never contact your customers about it. A vendor's own incident notice comes to you under your contract with that vendor.

When the engagement ends

StepWhat happens
Access removedEvery Tez user and role removed from every system, checked against the access record
Credentials endedEvery key, app authorisation and service account we created is revoked, or rotated and handed to you
Nothing in our nameAnything that ended up in a Tez name is transferred to you first — by design there should be nothing
Handover packThe workflow register, data sheets, settings record, change log and plain-English run notes, so your team or the next provider can keep it running
Written confirmationWithin 30 days of the end of the engagement

Everything we build is yours — documented and portable. If we part ways, it keeps working and your team knows how it runs.

A6

Limits

What this document is not

  • 01 · Not legal advice — Your counsel or compliance officer decides how your industry's rules apply to your business. This document tells them what we do so they can.
  • 02 · Not a SOC 2 report — We do not hold a SOC 2 attestation. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
  • 03 · Not the vendor — We do not run the AI vendors' systems or set their terms. Their security, retention, outages and incidents are governed by your contract with them. We are not a reseller, partner or certified provider of any AI vendor.
  • 04 · Your obligations stay yours — Using AI tools does not move your duties to us: licensing, supervision, record keeping, privacy notices and your staff's use of AI remain your business's responsibility. We build to them, as your industry's page sets out.
  • 05 · Not a promise about AI output — AI tools can be wrong, and confidently so. That is why anything that needs a judgement has a person in the loop, and why no workflow makes a decision your business would otherwise make.
  • 06 · Not permanent — Current as of October 2026. Vendor terms and the rules on AI change often. We review this document at least once a year, and whenever a vendor term or rule it relies on changes.

A7

Title

What your industry's rules mean for your AI tools

A title or settlement company holds nonpublic personal information on every party to a closing, and moves their money. Federal and state rules treat it as a financial institution that must oversee every vendor reaching that data, and the industry's own Best Practices expect written wire procedures and a security plan that covers service providers. AI tools add a specific risk here: an assistant connected to your inbox reads every email, including a forged one asking to change wiring instructions. And whatever an AI tool drafts for agents and lenders is marketing under the kickback rules. These are the rules that bear on your AI tools, and what we do about each.

RuleWhat it means for AI toolsHow we handle it
ALTA Best Practices 4.2, Pillar 2 — wire procedures [1]Outgoing wire instructions must be verified independently of the message that carried them, and consumers warned about wire fraud. An AI tool that summarises, drafts or acts on payment instructions sits inside that procedure.No AI tool drafts, sends, changes or confirms wiring instructions, and no workflow acts on an email about payment. Messages about wires are routed to your verification procedure unchanged. Your wire-fraud warning is a locked block in customer templates.
ALTA Best Practices 4.2, Pillar 3 — security plan and service providers [1]Your written security plan, background checks and service-provider oversight should cover anyone reaching nonpublic personal information — AI vendors and outside engineers included. Underwriters and lenders audit against it.We supply what your plan needs: the access record, settings record and our background-check confirmation, ready for underwriter and lender questionnaires.
FTC Safeguards Rule, 16 CFR Part 314 [2]Settlement services are financial institutions under the rule: oversee service providers, require safeguards by contract, notify the FTC within 30 days of a qualifying incident involving 500 or more consumers.Incident notice to you within 72 hours at the latest. Multi-factor authentication on every Tez sign-in.
NAIC Model 668; New York 23 NYCRR Part 500 [3][4]In adopting states and in New York, your 72-hour notice to the commissioner or DFS can start from what a vendor tells you.We tell you within 72 hours at the latest, with what we know, so your clock starts with facts.
Regulation P 1016.11 and 1016.13; NAIC Model 672 [5][6]Information shared with a service provider may be used only for the contracted purpose.Our use is limited to your engagement, in writing. We record whether each AI vendor's terms allow any other use, and set the controls with you.
RESPA section 8 and Regulation X 1024.14; state title anti-inducement laws [7][8][9][10]Nothing of value may be given for referrals of settlement business, and several states bar gifts, paid meals or advertising for producers. AI tools drafting outreach to agents and lenders suggest exactly these.Drafts to agents, lenders and other producers offer nothing of value — no gifts, meals, co-marketing or rewards. Your counsel's approved wording governs producer outreach.
Fair Housing Act [11]Protected characteristics may not shape how people are treated.No AI tool targets, ranks or tailors outreach on protected traits or proxies for them.
TCPA, Do Not Call and CAN-SPAM [12][13]A message a workflow sends follows the same consent rules as one a person sends — to agents' mobiles as to consumers'.Workflows draft; a person sends, from your channels.
State privacy laws narrowing the GLBA exemption [14]Data outside the federal exemption, such as agents' records, can carry state access and deletion rights.We help locate and remove that data in the tools we set up, within your deadline.

In practice

  • An inbox assistant may sort incoming email and draft routine status updates for a closer to send. It flags anything mentioning wires or payment for your verification procedure and does nothing else with it.
  • A workflow may draft a closing checklist reminder to a buyer. It carries your wire-fraud warning and never states account details.
  • A follow-up to an agent who stopped sending files may say what your team does well. It offers no gift, meal or reward.
  • Closing packages, IDs and payoff letters stay in your production software, out of general AI workspaces.

A8

Sources

Where these rules come from

1. ALTA Title Insurance and Settlement Company Best Practices, Version 4.2 — https://www.alta.org/policies-and-standards/best-practices/ 2. FTC Safeguards Rule, 16 CFR Part 314 — https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314 3. NAIC Insurance Data Security Model Law, Model 668 — https://content.naic.org/sites/default/files/model-law-668.pdf 4. NYDFS Cybersecurity Regulation, 23 NYCRR Part 500 — https://www.dfs.ny.gov/cybersecurity/requirements 5. Regulation P, 12 CFR Part 1016 — https://www.ecfr.gov/current/title-12/chapter-X/part-1016 6. NAIC Privacy of Consumer Financial and Health Information Regulation, Model 672 — https://content.naic.org/sites/default/files/model-law-672.pdf 7. RESPA section 8, 12 U.S.C. 2607 — https://www.law.cornell.edu/uscode/text/12/2607 8. Regulation X, 12 CFR 1024.14 — https://www.ecfr.gov/current/title-12/chapter-X/part-1024/subpart-B/section-1024.14 9. Texas Insurance Code ch. 2502 — https://statutes.capitol.texas.gov/Docs/IN/htm/IN.2502.htm

  • 01California Insurance Code 12404 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=INS&sectionNum=12404. · Washington RCW 48.29.210 — https://app.leg.wa.gov/rcw/default.aspx?cite=48.29.210 · NYDFS Circular Letter 2a (2019) — https://www.dfs.ny.gov/industry_guidance/circular_letters/cl2019_02a
  • 02Fair Housing Act, 42 U.S.C. 3604 — https://www.law.cornell.edu/uscode/text/42/3604
  • 03Telephone Consumer Protection Act, 47 U.S.C. 227 — https://www.law.cornell.edu/uscode/text/47/227
  • 04FTC, CAN-SPAM Act: A Compliance Guide for Business — https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business
  • 05Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 — https://www.law.cornell.edu/uscode/text/15/chapter-94

Questions your counsel or compliance team wants answered first?

We go through this document on the free first session, and complete your security or due-diligence questionnaire during onboarding.

All industries