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 brokers, team leads and operations
Lead reactivation works the leads your brokerage has already paid for — buyers and sellers who asked about a home, were followed up once or twice, and then were not. We rank them by likelihood to book a conversation and work the list from the top, so your agents spend their time on the people most likely to sit down with them.
Every one of those contacts is regulated: by fair housing law, by your state’s license and advertising rules, and by federal and state telemarketing law — a law real estate is often sued under. This document sets out, control by control, how the engagement keeps your brokerage inside those rules, and which decisions stay with your broker. It is written to be read by your designated broker and filed with your vendor records.
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 agent’s desk. The sections after them are the detail your broker and counsel will check.
01
Commitments
Ten commitments, before the detail
- 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails and property addresses 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 broker’s approval — Your designated broker, or a licensed supervisor they name, approves every template before use. Our review sits on top of theirs, never in place of it.
- 03 · Your licensees do the talking — Messages go out from your channels under your brokerage’s licensed name. Every reply, call and conversation is handled by a licensed agent, never by us.
- 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
- 05 · Fair housing in the ranking and the wording — No protected characteristic, and no stand-in for one, is used to rank a lead. Every draft is checked for steering language before anyone sees it.
- 06 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment and no MLS data without your written instruction.
- 07 · Breach notice at once, in writing within 72 hours — We tell you as soon as we discover a breach, and set out the details in writing no later than 72 hours after.
- 08 · 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.
- 09 · A fee model checked against license law — A flat fee or a results-based fee. Section 14 sets out how each is treated under license law and RESPA, including where the results-based model is ruled out.
- 10 · Evidence on request — Every control here has something you can inspect. We complete your vendor questionnaire during onboarding.
02
The whole picture
The system on one page
The system works in three zones. Names, contact details and 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 broker approves and your agents send.
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 brokerage works its leads today
- 02 Agreement — Roles, purpose, subprocessors, breach notice
G1 - 03 Intake review — Lead sources, form consent wording, opt-outs
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, under contract, clients
G2 - 07 Swap names for IDs — A random ID; the key stays with you
- 08 Notes into facts — Fixed-list answers; protected traits dropped
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 — Your broker approves wording and disclosures
G5 - 15 Send — Re-checked at sending; under your name
G6
Learn (ongoing)
- 16 Record outcomes — Appointments, agreements, closings; a held-back group
- 17 Improve and report — Your ranking only; results you can check
G7
| Gate | When | What has to be true to pass | Who decides |
|---|---|---|---|
| G1 | Before any data | Signed agreement; your lead sources, form consent wording and opt-out records reviewed; your licensed states, designated broker and fee model confirmed | Your brokerage and Tez |
| G2 | As the list arrives | Opt-outs, Do Not Call, current clients, anyone under contract or represented by another brokerage, complaints and anyone hostile are set aside and never ranked | Software, on your rules |
| G3 | Before anything leaves your side | Only approved facts cross: no names, contact details, addresses, notes, exact figures or dates, and nothing about a protected characteristic | Software, checked by Tez |
| G4 | After a summary is drafted | No personal data, no steering, no promises, nothing the facts do not support | Software, then your agent |
| G5 | Before any outreach | Your designated broker approves the wording, the license disclosures and the batch | Your brokerage |
| G6 | At the moment of sending | Consent for that channel, Do Not Call, quiet hours in the lead’s time zone and state, opt-outs | Software, on your channels |
| G7 | Throughout, and at the end | Outcomes kept by random ID, used for your brokerage only, returned or destroyed at termination | Tez, 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.
| Factor | The question it answers | What it looks at, for a brokerage |
|---|---|---|
| Intent | How serious were they, and how long ago? | How far they got: inquiry, first call, showings, a listing appointment. Time since the last real conversation. Whether they replied before. How many follow-ups have already been tried. |
| Opening | Is there a real reason to get back in touch? | Why they paused, from a neutral list: timing, selling first, financing, nothing that fit. A date they named, such as a lease ending. Whether it has now passed. |
| Reachability | Can we reach them, and are we allowed to? | A working email or phone. Consent on file for each channel. Do Not Call status, and whether the three-month inquiry window has passed. |
| Fit | Can your brokerage still serve them? | A market your agents cover, as a yes or no decided on your side from the cities or counties you name. A transaction you handle. Not under contract elsewhere. |
How the ranking gets better
- 01It starts from your team’s experience — Your agents tell us how often each kind of paused lead comes back. Those estimates set the first odds. Until your results come in, the scores are educated estimates, and we say so.
- 02It corrects itself from your results — As appointments are booked, held or declined, the odds for each reason move toward what actually happened at your brokerage.
- 03It becomes a model of your brokerage alone — After about 300 recorded outcomes, the ranking is fitted to your brokerage’s results. It is never trained on, or pooled with, another brokerage’s data.
- 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back and not contacted for a set period. Comparing the two groups shows what the outreach actually changed, rather than what would have happened anyway.
05
A worked example
One lead, from your CRM to your agent
Marcus Reed is fictional. His record is shaped like a real buyer lead. Follow it through the four cards, left to right and top to bottom.
1 · Your CRM record (stays with you)
| Field | Value | Note |
|---|---|---|
| name | Marcus Reed | key table |
| phone | (512) 555-0137 | key table |
| m.reed@example.com | key table | |
| CRM ID | LD-204471 | key table |
| status | Toured homes, no offer | becomes a stage |
| note | Lease ends June 30. Pre-approval lapsed. Wife expecting, wants 3 bed near good schools | becomes facts |
| search | Round Rock 78664 · $380k–$420k | yes or no |
| last contact | February 9, 2026 | becomes days |
2 · What we receive (leaves your side)
| Field | Value | Note |
|---|---|---|
| ID | s_4Hw2pR8c | random |
| stage | Toured homes | Intent |
| days since | 239 | Intent |
| reason | Timing · financing not ready | Opening |
| condition | Yes, waiting on a date | Opening |
| reach | Email yes · text no consent | Reachability |
| fit | Market yes · buyer, residential yes | Fit |
| price tier | Off | optional |
Never leaves your side: his name, phone, email, CRM ID, the note, the area and price range, exact dates. Dropped altogether: the family detail and the school preference.
3 · What comes back (back to you)
| Field | Value | Note |
|---|---|---|
| ID | s_4Hw2pR8c | |
| score | 64 · tier B | |
| reasons | + named a date · + toured homes · − 239 days since contact | |
| reason line | Toured homes; paused for a date that has now passed. | fixed wording |
| summary | He paused until a date in early summer, which has passed, and his financing was not ready. A good opener is to ask whether he still plans to buy. | AI, checked |
| next step | Email, Saturday morning his time |
4 · In your CRM (stays with you)
| Field | Value | Note |
|---|---|---|
| record | Marcus Reed · tier B · 64 | matched back |
| fields | Reason line, summary and next step added to his record | |
| draft | “Hi {first_name}, …” from his agent, under your brokerage name | placeholder |
| flags | Text blocked, no consent · Do Not Call check required | G6 |
No text consent on file, so the next step is email. His inquiry is over three months old, so a Do Not Call check comes before any call. His agent sees his name here, in your own CRM, for the first time.
- 01His note became a few facts, and two details were dropped — “Lease ends June 30” left only as “waiting on a date.” The pregnancy and the school preference were dropped, not tiered: the first is familial status, a protected characteristic, and school preferences are a common route to steering.
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 broker approves anything sent.
The four checks at gate G4
- No personal data, no Tez name — No name, number, email or address. Names appear only as a placeholder, filled in on your side. The draft never names Tez I Solutions.
- No steering, no blockbusting — Nothing about who lives in a neighborhood, who a home suits, schools or safety. To sellers, nothing about a neighborhood changing.
- No promises — No price predictions, guaranteed results, commission figures, or claims that representation is free. It invites a conversation with your agent.
- Nothing made up, nothing you rule out — Every statement must trace back to a fact it was given, and your never-say list is blocked on top of these rules. Anything else fails.
07
Roles
Your broker stays in charge
Under state license law your designated broker supervises everything done in your brokerage’s name, advertising included, and only license holders may solicit buyers and sellers. Tez I Solutions holds no real estate license and works as your service provider: we rank, draft and run the tools; your licensees approve, send and talk. Where a state privacy law covers your brokerage, you are the business and we are your service provider; where none does, our agreement gives you the same terms. A brokerage on its own is not a financial institution under the Gramm-Leach-Bliley Act. If yours has an affiliated mortgage, title or escrow business, those records stay out of the export.
| Obligation | Your brokerage | Tez I Solutions |
|---|---|---|
| Supervision | Owns, through your designated broker | Works only within the scope you approve; keeps the draft, approved version and approver for every template |
| Approval of communications | Broker, or a licensee they name, approves before use | Submits templates; never alters approved wording |
| Conversations with leads | Your licensed agents | None. Replies are routed to your agents |
| Advertising disclosures | Sets the brokerage name and license wording | Builds them into every template |
| How leads were obtained | Warrants it in the agreement | Records the consent source and enforces it at send time |
| Fair housing | Owns your policies and training | Keeps protected characteristics and stand-ins out of ranking; checks every draft |
| Security of data we hold | Oversees | Operates the controls in sections 10 and 11 |
| Breach notice to individuals | Owns, under state law | Notifies you at once, in writing within 72 hours, and supports the investigation |
| Access and deletion requests | Receives and instructs | Executes within your deadline and confirms |
| Return or destruction | Instructs | Executes 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 carries signal, we keep a tier and drop the figure. Where a detail touches a protected characteristic, we drop it.
| Data | How it is handled | Reaches the AI model |
|---|---|---|
| Name, contact details, addresses | Held only in the encrypted key table on your side. Whether a home or search area is in your market is decided there, as a yes or no. | No; market as yes or no |
| Loan details, SSN, date of birth, IDs | Excluded from the export. If one appears in a note, the record is quarantined and the value removed. | No |
| Price range, home value, budget | Off by default. If your broker opts in, turned into a three-level tier on your side. The figure never leaves. | No |
| Inquiry, showing and contact dates | Converted to intervals — “8 months since last contact.” | Interval only |
| Lead source, stage, status, agent | Kept as categories; agent names replaced with codes. | As categories |
| Call and showing notes | Read on your side and turned into fixed-list answers (section 09). The note itself never leaves. | Fixed-list answers only |
| Consent records and opt-outs | Kept as an append-only history and enforced at send time. | No |
| Protected traits and stand-ins; MLS data | Household, children, marital status, age, health, religion, language, financing type. Not requested, not used to rank, not sent; dropped if found in a note. | No |
09
The privacy layer
Where AI sits, and what it sees
| Station | What happens | Holds or sees |
|---|---|---|
| 01 · Brokerage — Your CRM | Full records stay here. Only the agreed fields are read. | Holds: everything, as today |
| 02 · Secure env. — Separation, and notes into facts | A 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 summary | Ranking 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 sent | Names filled in on your side; consent checked; sent under your brokerage name. | Holds: the message, as your record |
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.
| Layer | What it does |
|---|---|
| 1 · Field allow-list | Only approved columns are read. Structured identifiers are separated by rule, not by a model’s judgement. |
| 2 · Identifiers stripped first | Phone numbers, emails, street addresses, account numbers, Social Security numbers, dollar amounts and dates are removed from a note before the local model reads it. |
| 3 · Fixed questions, fixed answers | The local model answers set questions — why they paused, whether they named a date, buying or selling — by choosing from a list your broker has seen, none of it about a protected characteristic. It cannot write free text. |
| 4 · Unsure means a person decides | An 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 scan | Every 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 brokerage 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 environment | On a Tez-operated workstation | |
|---|---|---|
| Where raw data sits | Your infrastructure; it never leaves your perimeter | An encrypted workstation operated by Tez, in a separate encrypted volume per brokerage |
| Access | You control it. We use a named, least-privilege account you can revoke at any time | One named individual, with multi-factor authentication |
| Network | Your controls | Outbound limited to the AI provider and your sending channels |
| Logging | Your logging stack | Access log kept for the engagement, provided on request |
| Suits | Brokerages with an IT team or managed IT provider | Brokerages and teams without capacity to host it |
Workstation standard, when Tez operates it
- Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each brokerage’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 brokerage’s volume is destroyed at termination and the destruction certified in writing.
11
Security and incidents
The controls, and what happens if one fails
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 | The program document |
| Encryption in transit and at rest | Configuration record |
| Multi-factor authentication on every account that touches your data | Account inventory |
| Access limited to named individuals, reviewed quarterly | Access list and review log |
| Access to your data logged | Log extract |
| Background check for anyone with access, on your request | Written confirmation |
| Raw data held only for the life of the engagement | Retention schedule |
| Return or destruction within 30 days of termination | Signed certificate |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The plan and its last review |
If something goes wrong
- 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
- 02 · Tell you at once, in writing within 72 hours — Which records and fields, what window, what we have done. Texas, for one, requires a vendor to notify the data owner immediately.
- 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation.
- 04 · Support your notice, never pre-empt it — Notice to individuals and regulators is your brokerage’s decision under state breach laws. We never contact your leads about it.
12
Fair housing and advertising
Your license rules cover every message
A text inviting a buyer or seller to talk to your agent is a statement about the sale of a home under the Fair Housing Act, and in Texas an advertisement. Every template is built to these rules.
- 01Fair housing in every message — No statement indicating a preference based on a protected characteristic (42 U.S.C. 3604(c), 24 CFR 100.75), no steering (100.70). HUD withdrew its 2024 digital ad guidance in 2025; the rules stand.
- 02Who gets contacted is covered too — Choosing who hears about housing can discriminate (100.75(c)(3)), and courts still apply disparate impact (Inclusive Communities, 2015). So the ranking uses no protected class or stand-in.
- 03Only licensees solicit — Texas bars unlicensed people from asking whether someone wants to buy or sell (TREC Rule 535.4(f)); California allows only general canvassing. We never phone leads; replies go to your agents.
- 04Your brokerage name on every message — Texas treats email and texts as ads carrying the broker’s name (TREC 535.154–535.155); California wants license number and broker on first contact (10 CCR 2773); Florida, the brokerage name (61J2-10.025).
- 05Buyer wording after the NAR settlement — For REALTOR® members and MLS participants, a written buyer agreement comes before any tour. So outreach invites a conversation, not a tour, quotes no commission and never calls representation free (Standard of Practice 12-1).
- 06No referrals to lenders or title — Messages never steer a lead to a lender, title or escrow company, and we take no payment from any of them (RESPA section 8). Every draft passes gate G4 first (section 06).
13
Consent
No evidenced consent, no text message
Real estate brokerages are frequent defendants under the Telephone Consumer Protection Act. In 2025 Anywhere Real Estate agreed to pay $20 million to settle a class action over its affiliated agents’ calls to numbers on Do Not Call lists. The brokerage answers for its agents, and the party that sends can be liable directly, so consent is enforced in software at the moment of sending, not left to policy.
- 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 agent calling directly — not text. An inquiry over three months old is no established business relationship for Do Not Call.
- 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 lead’s local time; 8am to 8pm and three calls a day on one subject in 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 agent is honoured on every channel and survives any re-import. Email unsubscribes 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 license law and RESPA, so your broker and counsel can choose with that in view. Tez I Solutions holds no real estate license.
Model A: Flat monthly fee
A fixed fee for operating the service. It does not depend on appointments, signed agreements, closings or commissions.
- License law. It holds up while our work stays on the unlicensed side: we rank, draft and run the tools; your licensees approve, send and hold every conversation. Florida also reaches fees for assisting in procuring prospects, so Florida brokerages should have counsel confirm it.
- RESPA. A fee for services actually performed, at market value, that does not change with closings (12 CFR 1024.14(g)).
- The simplest model to approve and supervise.
Model B: Results-based fee
A share of revenue attributed to reactivated leads, measured from your CRM’s own records — in practice, a share of commission on closed deals.
- License law. Paying an unlicensed person for procuring a prospect is prohibited in Texas (Occupations Code 1101.651), California (Business and Professions Code 10137) and Florida (Statutes 475.25(1)(h)).
- RESPA. A payment that rises with closings, for business sent to your brokerage, is what section 8 restricts. Its carve-out for referral fees covers agents and brokers only.
- Ruled out in those three states. Elsewhere, only if your broker and counsel confirm in writing that your state allows it.
15
Subprocessors and contract
Who else touches the data, and what we sign
| Subprocessor | What it holds | When |
|---|---|---|
| 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 instead | Every engagement |
| Your CRM and messaging providers | Messages, as they do today | Every engagement, under your contracts |
| Messaging provider operated by Tez | Phone numbers and message content | Only if you do not send through your own texting channel; then under your brokerage name, with every message copied to your CRM |
| Operator console hosting | Named in your agreement, with what it holds | Where 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 brokerage as the business, Tez as service provider; use limited to this engagement, and no licensed activity by Tez.
- No secondary use — No training, no sale, no reuse across clients, no enrichment and no MLS data without written instruction.
- Security exhibit and breach notice — The controls in sections 09 to 11 as binding terms; notice at once, in writing within 72 hours.
- Consent warranty — Your brokerage’s representation of how the leads were obtained, by source.
- Privacy requests — Access, correction and deletion within your deadlines, under any state privacy law that applies to your brokerage.
- Audit, return and destruction — Reasonable audit and questionnaire rights; return or certified destruction at termination.
16
Regulatory map
Each rule, and where it is addressed
| Rule | What it requires here | Section |
|---|---|---|
| Fair Housing Act, 42 U.S.C. 3604; 24 CFR 100.70, 100.75, 100.85 | No discriminatory statements or advertising, no steering, no blockbusting | 06 12 |
| Disparate impact: 24 CFR 100.500, Inclusive Communities | Practices judged by effect; why stand-ins are excluded | 04 12 |
| State fair housing laws | Additional protected classes, such as source of income | 04 08 |
| License law: Texas 1101.651, TREC 535.4; California 10131, 10137; Florida 475.25 | Only licensees solicit; no pay to unlicensed persons for broker acts | 07 12 14 |
| Advertising rules: TREC 535.154–535.155; 10 CCR 2773; Florida 61J2-10.025 | Brokerage name and license disclosures on messages | 07 12 |
| RESPA section 8, 12 CFR 1024.14 | No referral fees; pay only for services performed | 12 14 |
| NAR practice changes; Code of Ethics | Buyer agreement before touring; truthful advertising | 12 |
| TCPA and the Do Not Call rules | Consent, revocation, Do Not Call, quiet hours | 13 |
| State telemarketing laws | State consent, hours, frequency and registration rules | 13 |
| CAN-SPAM | Unsubscribe, address, accurate headers | 13 |
| State breach notification laws | Vendor notice to the data owner; owner’s notice to individuals | 07 11 |
| Massachusetts 201 CMR 17.00 | Written security program, encryption | 10 11 |
| State comprehensive privacy laws | Service-provider terms; access, deletion, no sale | 07 15 |
| NIST IR 8053, SP 800-188 | De-identification practice | 08 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 a public filing. They are listed here so your broker and counsel can check our reading against the text. Links were current in October 2026.
| Fair housing | Relied on for | Sections |
|---|---|---|
| Fair Housing Act, 42 U.S.C. 3604 (law.cornell.edu/uscode/text/42/3604) | Discriminatory statements and advertising (3604(c)); blockbusting (3604(e)) | 06 12 |
| HUD regulations, 24 CFR Part 100, incl. 100.70, 100.75, 100.85, 100.500 (ecfr.gov/current/title-24/part-100) | Steering, statements and advertising, choice of audience, blockbusting, disparate impact | 04 06 12 |
| Texas Dept. of Housing & Community Affairs v. Inclusive Communities Project, 576 U.S. 519 (2015) (law.cornell.edu/supremecourt/text/13-1371) | Disparate-impact liability under the Act | 12 |
| HUD, proposed rule on the disparate impact standard, 91 FR 1475, January 14, 2026 (govinfo.gov/content/pkg/FR-2026-01-14/html/2026-00590.htm) | HUD’s rule proposed for removal; questions left to the courts | 12 |
| HUD, Notification of withdrawal of FHEO guidance documents, effective September 17, 2025 (federalregister.gov/d/2026-06624) | Withdrawal of the April 2024 digital advertising guidance | 12 |
| California Government Code 12955 (leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV§ionNum=12955) | Additional protected classes, including source of income | 04 08 |
| New York Executive Law 296(5) (nysenate.gov/legislation/laws/EXC/296) | Additional protected classes, including age and lawful source of income | 04 08 |
| License law and advertising | Relied on for | Sections |
|---|---|---|
| Texas Occupations Code 1101.002 and 1101.651 (statutes.capitol.texas.gov/Docs/OC/htm/OC.1101.htm) | Procuring a prospect is a broker act; no pay to unlicensed persons for it | 07 14 |
| TREC, use of unlicensed individuals; Rule 535.4(f) (trec.texas.gov/article/can-you-use-unlicensed-individuals-help-your-texas-real-estate-transactions-it-depends) | Unlicensed persons may not contact people about buying or selling | 07 12 |
| TREC Rules 535.154–535.155, advertising (trec.texas.gov/article/what-you-need-know-comply-our-social-media-rules) | Email and texts are advertisements; broker name required | 12 |
| California Business and Professions Code 10131 and 10137 (leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10137&lawCode=BPC) | Soliciting buyers and sellers is a broker act; no pay to unlicensed persons for it | 07 14 |
| California DRE, Guidelines for Unlicensed Assistants (dre.ca.gov/files/pdf/faqs/guide_unlic_asst.pdf) | Limits on canvassing by unlicensed staff | 07 12 |
| Cal. Code Regs. tit. 10, 2773; Business and Professions Code 10140.6 (law.cornell.edu/regulations/california/10-CCR-2773) | License number and responsible broker on first-contact solicitations | 12 |
| Florida Statutes 475.01 and 475.25(1)(h) (leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0475/Sections/0475.25.html) | No fee to an unlicensed person for referring prospects or procuring them | 14 |
| Florida Administrative Code 61J2-10.025, advertising (flrules.org/gateway/ruleno.asp?id=61J2-10.025) | Licensed brokerage name in all advertising | 12 |
| NAR, settlement practice changes, effective August 17, 2024 (nar.realtor/the-facts) | Written buyer agreement before touring; no offers of compensation in the MLS | 12 |
| NAR, 2026 Code of Ethics and Standards of Practice (nar.realtor/about-nar/governing-documents/code-of-ethics/2026-code-of-ethics-standards-of-practice) | Truthful advertising; no “free” services (Standard of Practice 12-1) | 12 |
| Settlement services | Relied on for | Sections |
|---|---|---|
| Real Estate Settlement Procedures Act, section 8, 12 U.S.C. 2607 (law.cornell.edu/uscode/text/12/2607) | No kickbacks or referral fees for settlement-service business | 12 14 |
| Regulation X, 12 CFR 1024.14 (consumerfinance.gov/rules-policy/regulations/1024/14/) | Referral defined; pay for services actually performed; the agent-and-broker carve-out | 14 |
| Telemarketing and email | Relied on for | Sections |
|---|---|---|
| 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 liability | 13 |
| FCC rules, 47 CFR 64.1200; FCC Order DA 26-12, January 6, 2026 (docs.fcc.gov/public/attachments/DA-26-12A1.pdf) | Prior express written consent, Do Not Call, quiet hours, revocation; revoke-all delayed to January 31, 2027 | 13 18 |
| Telemarketing Sales Rule, 16 CFR Part 310 | Established business relationship: 18 months after a transaction, 3 months after an inquiry | 13 |
| National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us) | The two checks run before any number is contacted | 13 |
| Anywhere Real Estate, annual report for 2024 (Form 10-K), note on Bumpus v. Realogy Holdings Corp., N.D. Cal. (sec.gov/Archives/edgar/data/1398987/000139898725000020/R24.htm) | $20 million settlement over agents’ calls to Do Not Call numbers | 13 |
| Steidinger v. Blackstone Medical Services, No. 25-2398 (7th Cir., July 14, 2026) | Texts held outside the Do Not Call private right of action; other courts disagree | 13 |
| Insurance Marketing Coalition v. FCC (11th Cir., January 24, 2025); McLaughlin Chiropractic v. McKesson (U.S., June 2025) | One-to-one consent rule vacated; courts not bound by FCC readings | 13 |
| Florida Statutes 501.059 and 501.616; Texas SB 140 (2025), Tex. Bus. & Com. Code ch. 302 (leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0500-0599/0501/Sections/0501.059.html) | State consent, hours and frequency limits; texts as solicitation | 13 |
| 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 headers | 13 |
| Privacy, security and AI | Relied on for | Sections |
|---|---|---|
| FTC Safeguards Rule, 16 CFR 314.2 (ecfr.gov/current/title-16/chapter-I/subchapter-C/part-314) | Which real estate businesses count as financial institutions: settlement services and appraisers, not brokerage alone | 07 |
| Texas Business and Commerce Code 521.053 | A vendor holding data notifies the owner immediately after discovering a breach | 11 |
| 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 contracts | 10 11 |
| California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq. | Thresholds; business and service-provider roles; access, deletion and no-sale duties | 07 15 |
| 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 reversible | 08 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 reduction | 08 09 |
| Anthropic, Commercial Terms of Service (anthropic.com/legal/commercial-terms) | No training on commercial API inputs and outputs by default | 09 15 |
18
Limits
What this document is not
- 01Not legal advice — Your designated broker and counsel decide how these rules apply to your brokerage, in each state you work in. 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 provide the policies and evidence behind each control instead.
- 03Not a brokerage — Tez I Solutions holds no real estate license, represents no buyer or seller, negotiates nothing, and does not talk to your leads about any home or transaction.
- 04Not a fair housing audit — Because we never collect or infer protected characteristics, we cannot measure results by protected class ourselves. We show your broker the reason behind every rank so your brokerage can review them.
- 05Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s consent revocation rules and HUD’s disparate-impact rule among them. We review this document at least once a year and whenever a rule it relies on changes.
- 06Not a promise of results — A score says which leads to contact first, not who will book. Until your brokerage’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
| Item | Who owns it | How we handle it |
|---|---|---|
| AI subscriptions and workspaces | Your business — in its name, on its payment method | We 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 role | Your business keeps it, with at least one person on your side who is not us | We 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-in | A named user for each Tez person, in your directory or invited as a guest | Multi-factor authentication on. No shared logins. Never a password by email, text or chat. |
| Connections — API keys, app authorisations, service accounts | Created in your accounts, owned by you | Each 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 accounts | Their owners | Not 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
| Obligation | Your business | Tez I Solutions |
|---|---|---|
| Contracts with AI vendors | Holds them; the vendor processes your data under them | Reads the data terms and records them for you (A4) |
| Who on your team uses which tool | Decides | Sets up the seats and permissions you decide |
| Approval of workflows and changes | Approves before anything goes live | Proposes, documents and builds; never switches on without approval |
| Review of customer-facing output | Your people review before sending | Builds the review step into the workflow |
| Industry rules — licensing, records, supervision, privacy notices | Owns them | Builds to them as set out on your industry's page (A7) |
| Security of the access we hold | Oversees | Operates the controls in A5 |
| Notice to customers or regulators after an incident | Decides | Tells you within 72 hours and supports the investigation |
| Privacy requests from your customers | Receives and instructs | Helps 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.
| Workflow | Reads | Writes | Who sees the result | Human in the loop |
|---|---|---|---|---|
| Morning summary of new inquiries | CRM records created in the last 24 hours: name, source, service asked about, notes | One summary in the office manager's inbox | Office manager | Read before anyone acts on it |
| First-draft reply to a quote request | The single inquiry being answered; your approved reply templates and brand voice | A draft in the shared inbox — never sent | The person replying | Edited and sent by a person |
| Meeting notes to CRM | The transcript of a meeting the attendees agreed to record | A note on the matching CRM record | The account owner | Checked 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
| Check | What has to be true |
|---|---|
| Data sheet | Approved by you, in writing |
| Access | The connection reaches only what the sheet lists |
| Test | Run on made-up records, or on a small set of real ones you choose, with the results shown to you |
| Human in the loop | Marked 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 |
| Owner | A named person on your side who can pause it |
| Documentation | Written 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.
| Vendor | What its page said | Where |
|---|---|---|
| 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 — API | Data 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 plans | Read 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 Workspace | Your 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 software | Each 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.
| Record | What it holds |
|---|---|
| Access record | Every Tez sign-in and every connection we created: system, role or scope, date added, date reviewed, date removed |
| Settings record | Each tool's plan, data terms as read on a given date, and the controls set (A4) |
| Workflow register | Every live workflow, with its approved data sheet (A3), its owner on your side and its documentation |
| Change log | Every change to a live workflow or connection: what changed, why, when, who approved it |
| Training record | Who 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
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 | The program document |
| Multi-factor authentication on every account we use to reach your systems | Access record |
| Access limited to named individuals, reviewed with you quarterly | Access record and review log |
| Tez devices: full-disk encryption, screen lock, current patches, endpoint protection | Configuration 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 ends | Written procedure |
| Background check for anyone with access, on your request | Written confirmation |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The 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
| Step | What happens |
|---|---|
| Access removed | Every Tez user and role removed from every system, checked against the access record |
| Credentials ended | Every key, app authorisation and service account we created is revoked, or rotated and handed to you |
| Nothing in our name | Anything that ended up in a Tez name is transferred to you first — by design there should be nothing |
| Handover pack | The 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 confirmation | Within 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
Real estate
What your industry's rules mean for your AI tools
The rule that matters most for a brokerage's AI tools is fair housing. AI tools write listing descriptions, neighbourhood summaries and buyer follow-ups, and they reach for phrases — "perfect for young families," "a safe area," "great schools nearby" — that can be discriminatory statements or steering under federal and state law. The second is licence law: talking to someone about buying or selling is licensed work, and a chatbot doing it is doing it for your brokerage. These are the rules that bear on your AI tools, and what we do about each.
| Rule | What it means for AI tools | How we handle it |
|---|---|---|
| Fair Housing Act, 42 U.S.C. 3604; 24 CFR 100.70, 100.75, 100.85 [1][2] | Statements and advertising may not indicate a preference based on a protected class, and agents may not steer buyers toward or away from areas. An AI tool that describes who a home "suits," or suggests neighbourhoods by who lives there, can do both. | Fair housing rules are written into every tool's instructions: describe the property, not the people. Drafts with words about family status, religion, origin, disability or neighbourhood character are flagged for your review. No assistant recommends areas to a buyer. |
| Disparate impact — 24 CFR 100.500; Inclusive Communities [2][3] | Practices are judged by their effect, not only their intent. A workflow that decides who gets follow-up, or which listings a contact sees, by stand-ins such as zip code can have a discriminatory effect. | No AI tool targets, ranks or filters contacts on protected traits or close proxies for them. Any workflow that sorts people is described to your broker before it goes live. |
| State fair housing laws — California, New York and others [4][5] | Some states protect more classes, such as source of income or age. | Your states' extra classes are added to the tools' instructions. |
| Licence law — Texas 1101.651 and TREC 535.4; California 10131 and 10137; Florida 475.25 [6][7][8][9] | Contacting people about buying or selling is a broker act, and unlicensed persons may not do it. A chatbot or workflow that does it is speaking for your brokerage. | AI tools draft; a licensed agent reviews and sends anything about buying or selling. A website assistant takes contact details and passes them to an agent; it does not discuss price, terms or representation. |
| Advertising rules — TREC 535.154–535.155; 10 CCR 2773; Florida 61J2-10.025 [10][11][12] | Emails and texts are advertisements. Brokerage name, and in California the licence number on first-contact solicitations, are required. | Your brokerage name and numbers are set in the tools' instructions and every template, for each state. |
| NAR practice changes and Code of Ethics [13][14] | Members need a written buyer agreement before touring, and advertising must be truthful — no "free" services. | A scheduling workflow does not book a buyer's tour until your system shows a signed buyer agreement. Drafts make no "free" offers. |
| TCPA, Do Not Call and CAN-SPAM [15][16] | A message a workflow sends follows the same consent rules as one a person sends. Agents' calls to Do Not Call numbers have led to large settlements. | Workflows draft; a person sends, from your channels. A workflow that sends on its own is built only on written request, with consent and Do Not Call checks in it. |
| State breach and privacy laws — Texas 521.053 [17] | A vendor holding data must tell the owner immediately in Texas. AI tools holding lead data are part of what a breach could expose. | We tell you at once, and in writing within 72 hours. Help with access and deletion requests in the tools we set up. |
In practice
- An assistant may draft a listing description from the property facts. It describes rooms, features and distances — not who the home is "ideal for" — and an agent approves it.
- A workflow may draft a check-in to a buyer who went quiet. It suggests homes by the criteria the buyer gave, never by who lives in an area.
- A website chat may collect a visitor's name, number and what they are looking for, and hand it to an agent. It does not answer questions about price, offers or commission.
- Transaction files with financial or identity documents stay in your transaction-management system and out of general AI workspaces.
A8
Sources
Where these rules come from
1. Fair Housing Act, 42 U.S.C. 3604 — https://www.law.cornell.edu/uscode/text/42/3604 2. HUD regulations, 24 CFR Part 100 — https://www.ecfr.gov/current/title-24/part-100 3. Texas Dept. of Housing & Community Affairs v. Inclusive Communities Project, 576 U.S. 519 (2015) — https://www.law.cornell.edu/supremecourt/text/13-1371 4. California Government Code 12955 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV§ionNum=12955 5. New York Executive Law 296 — https://www.nysenate.gov/legislation/laws/EXC/296 6. Texas Occupations Code 1101.002 and 1101.651 — https://statutes.capitol.texas.gov/Docs/OC/htm/OC.1101.htm 7. TREC, use of unlicensed individuals (Rule 535.4(f)) — https://www.trec.texas.gov/article/can-you-use-unlicensed-individuals-help-your-texas-real-estate-transactions-it-depends 8. California Business and Professions Code 10137 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=10137&lawCode=BPC 9. Florida Statutes 475.25 — https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0475/Sections/0475.25.html
- 01TREC Rules 535.154–535.155, advertising — https://www.trec.texas.gov/article/what-you-need-know-comply-our-social-media-rules
- 02Cal. Code Regs. tit. 10, 2773 — https://www.law.cornell.edu/regulations/california/10-CCR-2773
- 03Florida Administrative Code 61J2-10.025 — https://www.flrules.org/gateway/ruleno.asp?id=61J2-10.025
- 04NAR, settlement practice changes, effective August 17, 2024 — https://www.nar.realtor/the-facts
- 05NAR, 2026 Code of Ethics and Standards of Practice — https://www.nar.realtor/about-nar/governing-documents/code-of-ethics/2026-code-of-ethics-standards-of-practice
- 06Telephone Consumer Protection Act, 47 U.S.C. 227 — https://www.law.cornell.edu/uscode/text/47/227 · Anywhere Real Estate, Form 10-K for 2024, note on Bumpus v. Realogy Holdings Corp. — https://www.sec.gov/Archives/edgar/data/1398987/000139898725000020/R24.htm
- 07FTC, CAN-SPAM Act: A Compliance Guide for Business — https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business
- 08Texas Business and Commerce Code 521.053 — https://statutes.capitol.texas.gov/Docs/BC/htm/BC.521.htm