How we handle your customers’ data

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.

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

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.

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)

2 · What we receive (leaves your side)

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)

4 · In your CRM (stays with you)

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.

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.

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.

09

The privacy layer

Where AI sits, and what it sees

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.

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.

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

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

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

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.

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.

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

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

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.

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

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.

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.

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

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

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.

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