Mortgage & Lending

Industry Summary

Originators, brokers, servicers, and secondary market participants handle highly sensitive borrower and collateral data
Regulated by GLBA, FCRA, HMDA, GDPR, and investor/agency requirements (e.g., FNMA/FHLMC, Ginnie Mae)
Data flows span POS/LOS, appraisal/title/MI vendors, credit bureaus, eClose/eVault/MERS, and servicing platforms
Threat actors include FIN groups (fraud/extortion), APTs (data theft), affiliate/insider fraud, and BEC/social engineering crews
Common tactics: portal credential theft, supply-chain compromise of LOS/DocGen, data exfiltration from cloud stores, and wire fraud at closing

1. Protect Borrower Onboarding & POS Portals

Problem
Borrower portals collect identity and financial data during application (pre-qual to full 1003), making them prime targets for takeover.

Data in Scope
PII, SPI, Financial (e.g., full name, SSN, DOB, address, phone/email, income, assets, bank statements, device ID)

Ubiq Controls Applied
Encrypt sensitive fields and uploaded docs at ingestion; tokenize borrower IDs; bind sessions to device signals.

IAM / Access Policy Logic
Only POS services and KYC/AML engines decrypt; brokers/LOs see masked identifiers unless elevated for verification.

Outcome / Impact
Mitigates account takeover, reduces breach blast radius, and supports KYC/FCRA compliance.

Threat Type
Account Takeover / Data Theft — FIN actors abuse stolen credentials, perform credential stuffing and session hijack; tactics include phishing, MFA prompt bombing, and API scraping.

2. Secure LOS Records & Core Loan File Documents

Problem
The LOS stores the authoritative loan file and documents (e.g., 1003, W-2s, pay stubs, 1099s, 4506-C, bank statements) attractive for identity fraud.

Data in Scope
PII, SPI, Financial (e.g., SSN, TIN, income, account/routing, employment history, property address)

Ubiq Controls Applied
Field-level encryption for PII/SPI; encrypt document blobs; tokenize loan numbers for cross-system joins; tamper-evident logs.

IAM / Access Policy Logic
Only loan processors/underwriters with case assignment decrypt; admins and DBAs receive masked views.

Outcome / Impact
Prevents mass exfiltration and limits insider over-reach while preserving LOS functionality.

Threat Type
Data Exfiltration / Insider Misuse — FIN groups and insiders leverage over-privileged LOS roles, LOTL tools, and export functions to siphon loan files.

3. Tokenize Credit Bureau Pulls & Score Data

Problem
Tri-merge credit reports and scores are replicated across systems for underwriting and pricing, expanding exposure.

Data in Scope
SPI, Financial (e.g., SSN, tradelines, inquiries, FICO/industry scores, adverse items)

Ubiq Controls Applied
Tokenize bureau file numbers and SSNs; encrypt score/factor reason codes; segregate keys per investor program.

IAM / Access Policy Logic
Only automated DU/LP/pricing and adverse action workflows detokenize; analysts see pseudonymized aggregates.

Outcome / Impact
Retains underwriting accuracy while reducing privacy and FCRA risk in downstream analytics.

Threat Type
Data Theft / Compliance Evasion — FIN groups target bureau integrations and SFTP drops; tactics include API key theft and scheduled job hijack.

4. Minimize & Mask Data Shared with Appraisal/Title/MI

Problem
Third-party vendors (AMC/appraisers, title, flood cert, MI) often receive more PII than necessary.

Data in Scope
PII, Property (e.g., borrower name, last-4 SSN, subject address, parcel/APN, flood zone)

Ubiq Controls Applied
Purpose-bound tokenization; redact/mask non-essential fields in vendor packages; encrypt payloads in transit/at rest.

IAM / Access Policy Logic
Vendor portals receive least-privilege, masked datasets; re-identification permitted only by compliance escrow service.

Outcome / Impact
Reduces vendor breach impact and aligns with data minimization obligations.

Threat Type
Supply-Chain Compromise — UNC/FIN actors breach vendor portals to harvest PII/property data; tactics include spear-phishing and credential reuse.

5. Encrypt Collateral Data: Appraisals, Photos & Geospatial

Problem
Appraisal photos, floorplans, geotags, and valuation models reveal personal and property details exploitable for fraud.

Data in Scope
Property, PII (e.g., interior/exterior photos, GPS metadata, appraisal PDF/XML, UAD fields, AVM outputs)

Ubiq Controls Applied
Encrypt media files and UAD fields; strip/cryptographically mask EXIF; tokenize appraisal IDs across systems.

IAM / Access Policy Logic
Only collateral review and QC services decrypt; brokers/agents see watermarked, masked renders.

Outcome / Impact
Prevents sensitive collateral leakage and supports investor data handling rules.

Threat Type
Data Leakage / Recon — FIN/APT actors scrape appraisal stores and object storage; tactics include cloud misconfiguration and signed URL abuse.

6. Protect Closing Packages & Wire Instructions

Problem
Settlement statements and wire instructions are frequent BEC targets, resulting in irrevocable fund diversion.

Data in Scope
PII, Financial (e.g., payoff statements, routing/account numbers, settlement agent wiring, closing disclosures)

Ubiq Controls Applied
Encrypt wire fields; bind instructions to transaction tokens; out-of-band verification workflows; signed, time-bound links.

IAM / Access Policy Logic
Only funding/closing systems decrypt; any change to wiring requires dual control and step-up auth.

Outcome / Impact
Reduces wire fraud and improves auditability of last-mile funding.

Threat Type
BEC / Social Engineering — Criminal crews spoof parties and alter wiring; tactics include mailbox rule abuse, PDF tamper, and supplier impersonation.

7. Secure eClose, eNote, eVault & MERS Transfers

Problem
Electronic promissory notes and registration events are high-value assets; compromise undermines collateral integrity.

Data in Scope
Financial, Legal (e.g., SMART Docs, eNote hashes, custodian references, MERS MIN, transfer history)

Ubiq Controls Applied
Encrypt eNote artifacts; store hashes with verifiable chains; segregate keys per custodian; sign/verify MERS messages.

IAM / Access Policy Logic
Only eVault services and authorized custodians decrypt; MERS actions require role-based approvals and attestation.

Outcome / Impact
Preserves negotiability and trust in electronic collateral.

Threat Type
Infrastructure / Integrity Attack — Sophisticated actors target eVault APIs and registries; tactics include API token theft and replay to forge transfers.

8. Pseudonymize Loan Tapes for Secondary/Investor Delivery

Problem
Loan tapes and stratification datasets shared with investors contain borrower attributes that enable re-identification.

Data in Scope
PII, Financial (e.g., LTV, DTI, FICO, geography, income bands, delinquency history)

Ubiq Controls Applied
Pseudonymize borrower and loan IDs; bucket rare attributes; encrypt files at rest and transit; watermark per-recipient.

IAM / Access Policy Logic
Investors receive de-identified tapes; re-linking keys held by issuer under legal controls.

Outcome / Impact
Enables pricing/hedging while protecting borrower privacy and meeting investor guidelines.

Threat Type
Third-Party Data Exposure — FIN actors breach investor portals; tactics include credential reuse, portal scraping, and S3/listing enumeration.

9. Protect Servicing, Escrow & Hardship/Forbearance Data

Problem
Servicing platforms store payment histories, escrow details, loss-mitigation and hardship documents, attractive to fraudsters.

Data in Scope
PII, Financial (e.g., payment tokens, bank accounts, escrow analyses, forbearance docs, hardship letters)

Ubiq Controls Applied
Encrypt payment instruments and hardship docs; tokenize borrower/loan keys across call center, IVR, and portals.

IAM / Access Policy Logic
Only servicing ops and loss-mitigation teams decrypt; CSRs see masked instruments and limited history.

Outcome / Impact
Limits exposure across high-volume servicing operations and call centers.

Threat Type
Extortion / Data Theft — FIN groups deploy ransomware and exfiltrate servicing data; tactics include phishing into helpdesk/VDI and data staging in cloud shares.

10. Control Exposure in Pipeline, Risk & HMDA Dashboards

Problem
BI dashboards aggregate pipeline, pricing, HMDA, and strat data; misconfiguration leaks PII and sensitive attributes.

Data in Scope
PII, Financial, Regulatory (e.g., loan pipeline, pricing hits, HMDA fields like race/ethnicity, census tract)

Ubiq Controls Applied
Tokenize identifiers in the warehouse; dynamic masking by role; row-level security and jurisdictional filters; encrypted extracts.

IAM / Access Policy Logic
Business users view masked metrics; compliance and fair-lending teams may access detokenized views with approval.

Outcome / Impact
Prevents inadvertent disclosure while enabling analytics and regulatory reporting.

Threat Type
Cloud Misconfiguration / Enumeration — FIN/APT actors harvest exposed dashboards or exports; tactics include token reuse, unsecured endpoint discovery, and API scraping.