Smart LOA Privacy Policy

1. Introduction

Smart LOA LLC (“Smart LOA,” “we,” “us,” or “our”) provides an AI-powered loan officer assistant platform that automates document collection, review, and borrower communication for mortgage loan officers and their clients (“Borrowers”). This Privacy Policy explains what information we collect, how we use it, how we protect it, and what rights you have regarding your information.

This policy applies to loan officers who use the Smart LOA platform (“Users”) and to borrowers whose information is submitted through the platform in connection with a mortgage application (“Borrowers”).

Because Smart LOA collects names, employment information, SSNs, tax returns, pay stubs, and bank statements, this data is classified as nonpublic personal information (“NPI”) under the Gramm-Leach-Bliley Act (“GLBA”). Smart LOA operates as a service provider/vendor to the loan officer or lender, who is the financial institution for GLBA purposes. Users (loan officers/lenders) are responsible for their own consumer-facing GLBA notices to Borrowers, and Smart LOA’s obligations run through the safeguards described in this Privacy Policy and our Data Processing Agreement.

2. Information We Collect

2.1 Information Collected from Loan Officers (Users)

• Name, email address, login credentials
• Employer/brokerage information

This information, along with all application data entered through the intake form, is stored in a secure database separate from the document storage described in Section 5.

2.2 Information Collected from or About Borrowers

Identity Information

• Full name, Social Security Number or ITIN, date of birth
• Residency type, marital status
• Contact information: email, cell phone, work phone, home phone
• Current and previous mailing address
• Number and ages of dependents

Financial Information

• Income (employment income, bonuses, commissions, and other income types)
• Assets (bank accounts, balances, account numbers, institution names)
• Liabilities (creditor information, balances, monthly payments, account status)
• Real estate owned (property details, mortgage balances, monthly expenses)
• Estimated credit score

Government Monitoring Information

Federal law requires that we ask for demographic information (ethnicity, sex, and race) in connection with certain mortgage applications, in order to monitor compliance with equal credit opportunity, fair housing, and home mortgage disclosure laws. This information is collected in accordance with the Home Mortgage Disclosure Act (Regulation C) and the Equal Credit Opportunity Act (Regulation B). You are not required to provide this information, and we may not discriminate against you based on whether you choose to provide it.

Documents

• Driver’s license or other government-issued identification
• Social Security card
• Residency documentation (Green Card, passport, employment authorization card)
• Tax returns and W-2 forms
• Pay stubs
• Bank statements
• Mortgage statements, homeowners insurance documentation, HOA documentation
• Credit reports

2.3 How Information Is Collected

• Directly from loan officers through the application intake form
• Directly from Borrowers via email, after affirmatively agreeing to these terms on a consent landing page (see Section 4)
• In some cases, from a third party submitting on the Borrower’s behalf, for example, a Realtor or a member of the loan officer’s team, such as when a Borrower drops off physical documents at an office instead of emailing them directly

3. How We Use Information

We use the information collected to:

• Facilitate document collection for the mortgage loan application process
• Automatically classify and organize submitted documents
• Identify missing or outstanding documents and generate status summaries for the loan officer’s review
• Communicate with Borrowers regarding required documentation, in their preferred language
• Comply with applicable federal and state law, including mortgage industry recordkeeping requirements

Smart LOA supports document collection and organization. The loan officer independently processes the loan and makes all lending-related determinations. Smart LOA’s AI does not review Borrower data to make lending, underwriting, or eligibility decisions.

4. Automated Processing, Consent, and AI Disclosure

Smart LOA uses artificial intelligence, specifically Amazon Bedrock running Anthropic’s Claude model, to classify submitted documents, identify missing items, and manage borrower follow-up communication. The AI performs exactly three functions: extracting data from documents, classifying documents, and generating responses to borrower emails within set parameters. Each of these is processed as a single, one-time request; the AI provider does not retain or store any data after processing, and no custom or fine-tuned models are used, only prompt-based instructions.

Borrower-facing communications are sent by an AI assistant. Each loan officer’s assistant has its own name (for example, “Lily”); the assistant is always an automated system, not a human employee. This disclosure appears in this Privacy Policy, our Terms of Service, and our AI Use Policy.

Consent process: before any document is transmitted or the AI has any interaction with a Borrower, the Borrower is sent a link to a consent landing page disclosing this Privacy Policy, our Terms of Service, and our AI Use Policy. Only after the Borrower affirmatively agrees does Smart LOA send the automated document checklist and begin collecting documents.

5. How Information Is Stored and Protected

Smart LOA uses two separate data stores:

• Documents (identification, tax returns, bank statements, and similar files) are stored exclusively in Microsoft OneDrive, in a dedicated Microsoft 365 account provisioned for each loan officer. The Smart LOA application itself does not duplicate or separately store these documents; the portal reads directly from OneDrive, and viewing a document in the portal generates a temporary access link that expires after approximately one hour rather than creating a permanent copy elsewhere.
• Application and account data (information typed into the intake form, including Borrower identity and financial details, plus User registration/login information) is stored in a secure database hosted on Amazon Web Services.

Documents and data are protected using the built-in encryption and security infrastructure provided by Microsoft and Amazon Web Services, including encryption of data in transit and at rest as part of these providers’ standard infrastructure. The smartloa.com domain has SPF, DKIM, and DMARC configured, which authenticate outgoing mail and help prevent spoofing.

Currently, Borrowers submit documents via email in response to automated requests. A loan-officer-side document upload feature is planned for a future product phase.

Access controls: administrative access to loan officer OneDrive and Outlook accounts, which includes the ability to view Borrower documents and PII, is limited to a small number of individuals on our development team.

6. Information Sharing and Third Parties

We may share information with:

• The loan officer and any co-borrower’s information as necessary to process the application
• Microsoft, which hosts our email (Outlook) and document storage (OneDrive) infrastructure
• Amazon Web Services, which hosts our application and database
• Anthropic, via Amazon Bedrock, whose Claude AI model performs document extraction, classification, and borrower communication. Per Amazon Bedrock’s terms of service, data processed through this AI is not retained or used by Anthropic or Amazon beyond the specific request.
• Our development team, who maintain administrative access to loan officer accounts as part of building, maintaining, and supporting the platform
• Lenders and underwriters, as necessary to complete the mortgage transaction
• Regulators or law enforcement, where required by law

Smart LOA may integrate with third-party loan origination systems in the future, beginning with ARIVE.

We do not sell Borrower information. We do not use Borrower information to train or improve AI models; each AI request is processed independently and no data is retained by the AI provider.

Our Circle Mortgage is treated as a regular platform User, like any other loan officer or brokerage using Smart LOA. Our Circle Mortgage staff or a Realtor may occasionally submit documents on a Borrower’s behalf, and this is covered under the standard User terms that apply to any loan officer or brokerage.

7. GLBA Notice

Smart LOA handles nonpublic personal information as defined under the Gramm-Leach-Bliley Act. As a service provider to loan officers and lenders, our role is to support Users’ own GLBA compliance obligations through the safeguards described in Section 5 and our Data Processing Agreement. Users retain responsibility for issuing their own GLBA privacy notices to their Borrowers.

8. Data Retention and Deletion

Borrower documents and data are retained unless and until deletion is requested by the User (loan officer) or the Borrower.

A loan officer may delete an individual Borrower’s application at any time. Doing so permanently and completely removes all associated documents and data from both OneDrive and Smart LOA’s database; nothing is archived or backed up separately after deletion.

To request deletion of your data, cancel a User account, or with any other data-related request, contact admin@smartloa.com.

9. Borrower Rights

Borrowers may:

• Request access to the information Smart LOA holds about them
• Request correction of inaccurate information
• Request deletion of their information, subject to Section 8

These rights are offered to all Borrowers regardless of state of residence.

10. Children’s Privacy

Smart LOA is not directed to individuals under the age of 18, and we do not knowingly collect information from minors.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to Users and, where applicable, Borrowers.

12. Contact Us

Questions about this Privacy Policy, or requests regarding your information, can be sent to admin@smartloa.com.