Written Cybersecurity Policies
An owner-approved policy set covering the areas DFS lists — sized for a small brokerage, not a 200-page template written for a bank.
We create the documentation New York's Department of Financial Services expects to see — policies, risk assessment, asset inventory, access reviews and your annual filing. Built with agentic AI. Reviewed line by line by Microsoft experts.
We work with independent mortgage brokers. Not banks, not retail or wholesale lenders — just brokers.
New York's cybersecurity regulation was written with large institutions in mind. But DFS carved out a limited exemption for small covered entities — and most independent mortgage brokers qualify. You qualify if you meet any one of these tests:
Qualifying isn't automatic. You must file a Notice of Exemption with DFS within 30 days of determining you qualify — and you still file an annual compliance certification (or acknowledgment of noncompliance) by April 15 every year.
Source: 23 NYCRR 500.19(a). Eligibility depends on your specific facts, including affiliates — we'll walk through it with you. This is general information, not legal advice.
Not required doesn't always mean not worth doing. We'll tell you plainly which of the optional items are worth it for your brokerage — and which aren't.
Examiners don't grade effort. They grade evidence. We produce the written program and the proof behind it, so when DFS asks, you hand it over.
An owner-approved policy set covering the areas DFS lists — sized for a small brokerage, not a 200-page template written for a bank.
A documented assessment of your real systems, vendors and data flows. Updated every year and whenever something material changes.
Every laptop, phone, mailbox and cloud app that touches borrower data — pulled straight from your Microsoft tenant, not guessed on a spreadsheet.
Who can see what, reviewed and signed off. Includes onboarding and offboarding procedures so departing staff lose access the same day.
A third-party service provider policy and due-diligence records for every vendor that touches your nonpublic information.
Multi-factor authentication and Conditional Access configured correctly in Microsoft 365 — with exports an examiner can actually read.
Annual cybersecurity awareness training, including social engineering, with completion records for your file.
A one-page, plain-English procedure for the 72-hour notice to DFS: who calls whom, and what gets reported.
Your Notice of Exemption and your April 15 certification or acknowledgment — prepared with you and ready to submit.
Email, files, Teams, identities, devices — for most brokers, nearly every piece of borrower data passes through Microsoft 365. That means your security posture is mostly your tenant's configuration.
The problem: Microsoft never stops changing. New policies, new security features, new licensing, and new names for old things. No human IT team could keep up, so most brokers are paying for security they already own and have never turned on.
Agentic AI changed that. AI agents can read a tenant's configuration, compare it to Microsoft's current guidance and the regulation, and draft both the fixes and the paperwork. That's how we lower your cost and raise your security at the same time.
Same product, new name. A few recent examples:
If you've ever felt lost in the Microsoft admin portals, it isn't you.
We use AI to save you money, and every piece of it is reviewed by a person who knows Microsoft and knows mortgage.
Thirty minutes. We learn how your brokerage runs and check whether the small-business exemption applies.
With your approval, AI agents review your Microsoft 365 configuration and gather evidence. Nothing changes without you.
Policies, risk assessment, asset inventory and procedures — drafted around what we actually found.
A Microsoft expert on our team reviews every document and recommendation before you see it.
You get the binder and the evidence. We help you keep it current and file on time every April.
Everything in IT changed when AI agents learned to do work that used to take a human helpdesk: password resets, setting up a new loan officer, pulling audit evidence, drafting policies. That work got faster — and it should have gotten cheaper.
If you're still paying your IT company what you paid in 2023, you should be getting a whole lot more for it. This is a good year to look at your entire technology stack: what you pay for, what you use, and what an AI-assisted team can handle for less.
That focus isn't a limitation. It's why we're better at this than a generalist IT firm.
We've worked inside origination, compliance, onboarding and the software vendors that serve this industry. You won't spend the first meeting explaining what a processor does.
We know the exceptions New York makes for small businesses, and we build programs sized for a 5- or 15-person shop — not a bank.
We tell you what you need and what you don't. In a market like this one, every dollar you don't spend on IT stays in your business.
New York has the strictest rules, so that's where we built our playbook. Everywhere else, the FTC Safeguards Rule applies to mortgage brokers — and we map your program to it too.
Most brokers are one audit away from a finding. Let's fix that before the examiner finds it.