AI tools are landing in escrow offices whether anyone planned for it or not. Officers draft emails, summarize files, and generate checklists with ChatGPT, Copilot, and other assistants. Some uses are fine. Some put client data, wire instructions, and regulatory exposure into a public AI system the office does not control.
This page gives you a complete policy template your office can adopt this week. Print it, mark it up, hand it to counsel, and make it yours.
Use this as a starting point. Have counsel and management adapt it before adoption.
The policy says do not trust AI output as the record. The office still needs to record what it reviewed before action.
A practical traffic-light system for deciding what goes into an AI tool and what does not. The data classification is based on the content, not the tool.
Generic, non-client-specific content that does not expose any file, party, or transaction data.
Office-internal content that may reference processes but must never include client names, file numbers, or transaction details. Output is a draft, not a decision.
Any content that contains or could expose client funds, personal identifiers, or transaction-specific instructions. This is the line that cannot move.
No client personally identifiable information (PII) may be entered into any public AI tool. This includes names, addresses, phone numbers, email addresses, Social Security numbers, loan numbers, and file numbers.
If a task requires referencing a client, sanitize the content first: replace real names with placeholders (e.g., “Client A”), remove all identifying details, and confirm no remaining text could identify the client before submitting to the AI tool.
Wire instructions, bank account numbers, routing numbers, and payoff demand details are strictly prohibited from entry into any public AI tool under any circumstances.
There is no business need that justifies putting wire or account data into a public AI tool. If a task seems to require it, stop and use an office-internal process instead.
Any AI-assisted output that will be used in a client-facing communication, filed in a transaction file, or relied upon for an operational decision must be reviewed by a manager or designated reviewer before use.
The reviewer must:
The review itself is the record. The office still needs to record what it reviewed before action.
Public AI tools (ChatGPT free tier, Copilot, public Gemini, etc.) process data on servers the office does not control. Content entered into these tools may be stored, logged, or used to train future models. Treat all public AI tools as external systems.
Private or enterprise AI tools (Copilot for Microsoft 365 with enterprise data protection, ChatGPT Team/Enterprise with data privacy controls) may offer stronger data protections. However, they are still AI tools, not escrow systems. The green/yellow/red framework still applies. Private deployment does not move red-zone content into the green zone.
The data classification (green/yellow/red) is based on the content, not the tool. A private tool does not make prohibited content safe to enter.
When AI-assisted output is used in a transaction file or client communication, the following must be documented:
This documentation goes in the file alongside the final output. The policy says do not trust AI output as the record. The office still needs to record what it reviewed before action.
AI output should not be stored as the authoritative record. The office’s reviewed and approved version is the record. The AI draft is working paper, not file evidence.
Have each staff member sign this form after reading and understanding the policy. Keep signed copies in personnel files.
AI USE POLICY ACKNOWLEDGMENT Office name: _______________________________ Employee name: _______________________________ I acknowledge that I have received, read, and understood the AI Use Policy for this office. I agree to: 1. Follow the Green/Yellow/Red framework for all AI tool use. 2. Never enter client PII, wire instructions, bank account numbers, or transaction-specific details into any public AI tool. 3. Submit all AI-assisted client-facing or file-bound output for manager review before use. 4. Document what was reviewed, what was changed, and what the office decided. 5. Report any accidental disclosure of client data to an AI tool to my manager immediately. I understand that violations of this policy may result in disciplinary action up to and including termination. Employee signature: ______________________ Date: __________ Manager signature: _______________________ Date: __________
Enter your name and work email and we’ll send you a print-ready version of this policy. We’ll also let you know when the policy is updated. No spam, no pitches.
This policy tells your staff what not to put into AI. But the policy also says something important: the office still needs to record what it reviewed before action. That record — what was checked, what stayed open, who decided — is the piece most offices do not have.
If you want to see what that record looks like on a real file, run the file test with one closed payoff demand. No live funds, no account numbers, no commitment. The office decides. Veto records the review.
The office decides. Veto records the review.
Veto does not approve, verify, authorize, guarantee, insure, or release funds. This policy template is provided as educational material, not as legal advice or a compliance product. Use this as a starting point. Have counsel and management adapt it before adoption.