Privacy Policy

Last updated: May 14, 2026

This Privacy Policy describes how FM Home Loans, LLC (also doing business as MR Capital Group), a New York–licensed residential mortgage lender (NMLS ID: 2212) (“FM Home Loans,” “we,” “us”), handles personal information about FM Home Loans personnel in connection with Helm, our internal pipeline management application.

Information We Collect

Identification & access

When you authenticate to Helm, we receive and process the following from Microsoft Entra ID single sign-on:

• Your Entra Object ID (an immutable user identifier)
• Your corporate email address and display name
• Your Encompass User ID (provided via your Entra profile extension attribute)

Application activity

• Authentication events (sign-in timestamps, source IP addresses, user-agent strings)
• Pages and loan records accessed within Helm
• Administrative actions taken within Helm
• Your notification preferences and saved views

Notification channel information (opt-in)

If you enable SMS, email, push, or in-app notifications, Helm collects and stores:

• Mobile phone number (only if you enable SMS notifications)
• Web Push subscription endpoints (only if you enable push notifications in your browser or installed app)
• Your per-event-type notification preferences and quiet-hours settings
• An audit record of your opt-in, including timestamp, IP address, and the consent text shown at the time you opted in

Loan and borrower information displayed in Helm

Helm displays loan, borrower, and property information sourced from FM Home Loans' loan origination system (Encompass). This information is the property of FM Home Loans and is governed by FM Home Loans' broader information-handling practices and all applicable laws and regulations, including the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and 23 NYCRR Part 500. Helm does not display borrower information to any user beyond the access scope established by that user's Encompass roles and access groups.

How We Use This Information

• To authenticate users and authorize access scoped to each user's Encompass roles and access groups
• To present each user's role-appropriate loan pipeline and related operational information
• To deliver notifications via the channels each user has explicitly opted into
• To maintain audit logs required for security, compliance, operational, and regulatory purposes
• To detect, investigate, and respond to suspected unauthorized access or security incidents

How We Share Information

Helm operates entirely within FM Home Loans' Microsoft Azure tenant. We engage the following sub-processors to operate Helm:

• Microsoft Azure — application hosting, database, identity (Entra ID), and supporting infrastructure
• Microsoft Graph API — email notification delivery
• Azure Communication Services — SMS notification delivery
• ICE Mortgage Technology (Encompass) — loan-system source of record

We do not sell, rent, or otherwise share personal information collected through Helm — including mobile phone numbers — with third parties for marketing purposes. We may disclose information when required by law, in response to lawful process, or to protect the rights, property, or safety of FM Home Loans, its personnel, or its customers.

SMS-Specific Practices

Helm's SMS notification feature is operated using toll-free number 1-844-778-0618. Mobile phone numbers collected through Helm are used solely to deliver Helm transactional notifications to the employee who provided the number.

You may opt out of all Helm SMS notifications at any time by:

• Replying STOP to any message received from 1-844-778-0618; or
• Disabling the SMS delivery channel in your Helm Notification Preferences page.

Reply HELP to any message from 1-844-778-0618 for help instructions. Message and data rates may apply per your mobile carrier plan. See the full Terms & SMS Consent page for the complete consent disclosure.

Retention

• Authentication and activity logs: retained in accordance with FM Home Loans' records retention policy and applicable regulatory requirements (including 23 NYCRR Part 500 minimums)
• SMS consent records: retained while the user is active and for at least seven (7) years thereafter, as required for regulatory recordkeeping
• Notification delivery records: retained for at least twenty-four (24) months
• Mobile phone numbers: deleted upon opt-out unless retention is required for regulatory, audit, or legal-hold purposes

Security

• Data is encrypted in transit (TLS 1.2 or higher) and at rest
• Access to Helm requires authentication via Microsoft Entra ID single sign-on with multi-factor authentication
• Authorization within the application is inherited from each user's Encompass roles and access groups
• Administrative actions and access events are audit-logged
• Helm is operated under FM Home Loans' cybersecurity program established pursuant to 23 NYCRR Part 500

Your Choices

Helm users are FM Home Loans personnel. With respect to information collected through Helm:

• Notification preferences: manage opt-ins, opt-outs, and quiet hours in your in-app Notification Preferences page
• Mobile number: update or remove in your Notification Preferences page; replying STOP to an SMS message also stops further SMS
• Access & correction requests: contact support@fmm.com

Changes to This Policy

FM Home Loans may update this Privacy Policy from time to time. Material changes will be communicated through Helm and/or corporate email. The effective date at the top of this page indicates the most recent revision.

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