Pre-approval emails and AI confidentiality: what a broker’s good-news email gives away in ChatGPT or Claude.

A pre-approval email is the message clients wait for, and brokers write it quickly because it is good news. It names the lender, the amount and the expiry, lists the conditions, and often adds personal guidance from the last conversation: how much to keep in savings, what to avoid before settlement, what a change in hours would do. Brokers paste the draft into ChatGPT or Claude to polish the tone. This page marks every item in a routine pre-approval email that the National Consumer Credit Protection Act and the Privacy Act bear on, and shows how the same email is drafted on Ermos inside the brokerage.

The pre-approval email to clients

Sent when the lender issues a conditional pre-approval and before the clients make an offer. The broker’s advice in it is part of the credit assistance covered by the best interests duty in sections 158LA and 158LE of the National Consumer Credit Protection Act.

From: Anita Menon   To:
Tue 27 Oct 2026, 11.05am   Subject: Your Southgate pre-approval is through

Hi Daniel and Sophie,

Good news.

The conditions.

Your savings.

Next.

Congratulations, and call me any time.

An invented email. The lender and the conveyancer are invented; the licence value is a placeholder. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the brokerage

  1. 1
    The clients

    Named. Everything below is identifiable. Privacy Act guide.

  2. 2
    The lender, amount, expiry and repayment

    The approval itself, its expiry and an indicative repayment. The household’s borrowing capacity, stated. Privacy Act guide.

  3. 3
    The conditions

    What the lender still needs: a payslip, a valuation, a gift letter and a card closure. Reveals the gift and the card the broker asked to be closed to make the numbers work. Privacy Act guide.

  4. 4
    The budget advice and the savings figures

    The deposit, costs and what remains after settlement. Personal advice drawn from the clients’ confidences and the broker’s own arithmetic. Privacy Act guide.

  5. 5
    The standard caveat

    Template wording saying that a pre-approval is conditional, is not an offer and is subject to change. The same paragraph goes to every client.

  6. 6
    A private plan mentioned on a call

    A possible change in one client’s working hours, reflecting family plans. Told to the broker so the loan fits, and not meant for anyone else. Privacy Act guide.

  7. 7
    The next steps and the conveyancer

    The property again, and a named conveyancer expecting the contract. The deal in progress. Privacy Act guide.

  8. 8
    Broker and licence

    Public register details. They tie the email to the licensee that owes the duty in section 158LA, and to the name a scammer would borrow.

What happens in Frontier Models (ChatGPT, Claude)

  • The whole document is transmitted to the provider’s servers. On personal plans the user cannot choose where it is stored or processed, and for the major providers that has generally meant outside Australia, under that country’s legal process. Some business plans offer storage in Australia, but the provider still receives the content.
  • On consumer tiers, prompts can be retained and used to train future models.
  • The provider’s staff and systems can reach the content under the provider’s own policies.
  • Once sent, the brokerage no longer controls it. Retention and deletion happen on the provider’s terms.

The same document on Ermos

Ermos Dominion

The document is drafted on a unit in your office, from your own templates and the client file. Every marked item stays on the unit, which keeps working with the internet switched off. Nothing in it is transmitted to an AI provider, so there is no disclosure to analyse: the confidentiality work is the same as for your file server.

Ermos Edge

Your documents, the index and your access boundaries stay on your own instance in an Australian data centre. When a staff member asks for this draft, only their question and the excerpts they are permitted to see go to a named Australian provider, who is contractually barred from keeping the content or training any model on it. Nothing is processed outside Australia.

Frontier Models (ChatGPT, Claude)Ermos EdgeErmos Dominion
Where the document is processedProvider servers, generally offshore on personal plansYour instance in an Australian data centre; answers generated in AustraliaThe unit in your office
Who can read itProvider staff and systems, under policyYour staff, within the boundaries you set. The named Australian provider processes only permitted excerpts, under contract, and keeps nothingYour staff only
Is it keptOn the provider’s termsKept on your instance; the provider is barred from retaining itStays on the unit
Can it train a modelOn consumer tiers, yesNo, by contractOnly your own unit learns from it, on your hardware

Part of AI data leakage in mortgage brokerages. See how this works in practice: Client correspondence on Ermos.

Common questions

Do ChatGPT and Claude use the information in a pre-approval email to clients?
The email goes to the AI company's servers and is processed there to produce a reply. As at October 2026, whether a conversation on a personal plan (ChatGPT Free, Plus or Pro; Claude Free, Pro or Max) can be used to train the models depends on a setting each user controls. Business plans (ChatGPT Business and Enterprise, Claude Team and Enterprise) and the developer APIs sit under commercial terms, and OpenAI and Anthropic each say they do not train on that content by default (OpenAI, Anthropic). On either product, the thumbs up and thumbs down buttons can send a whole conversation back for training. It states the clients' borrowing capacity, the card closure the broker asked for and a private plan to reduce working hours.
Is it safe to paste a pre-approval email to clients into ChatGPT or Claude?
No, because the email states what the household can borrow and what it has left. The Office of the Australian Information Commissioner (OAIC) recommends in its guidance on commercially available AI products that organisations do not enter personal information, and particularly sensitive information, into publicly available generative AI tools, because of the significant and complex privacy risks. Swapping the names does not remove the Tarrant Close purchase, the $868,000 approval, the conveyancer expecting the contract or the savings the clients want held after settlement. Removing names rarely makes a document anonymous. Information stays personal information while the person is reasonably identifiable, and the OAIC warns that information can be at risk of re-identification even when it has been de-identified or anonymised.
What if staff use their own ChatGPT or Claude account for a pre-approval email to clients?
The brokerage loses sight of the email the moment it leaves. On a personal plan the user cannot choose where conversations are stored or processed. Some business plans let an organisation choose to store data at rest in Australia (OpenAI), which still leaves the content with the AI company. Both companies can also review content that is flagged for safety or policy reasons. A pre-approval drafted from a personal account sits outside the brokerage's records and controls, so nobody there can see or manage what was sent. The brokerage could not tell the clients where their borrowing amount and the plan to reduce hours ended up.
How can a mortgage brokerage use AI for a pre-approval email without sending it to ChatGPT or Claude?
Ermos is built so the document stays under your control. On the Dominion AI unit it is drafted inside your office and none of it is sent to an AI provider. On Ermos Edge your documents and index stay on your own instance in an Australian data centre, and only the question and the excerpts the user is permitted to see go to a named Australian provider that is contractually barred from keeping them or training any model on them. The email is drafted from the lender's approval on the client file and the brokerage's own pre-approval template, with its standard caveat wording. The broker checks the amount, the expiry and every condition before it goes out.
What does the credit guide have to say about commissions?
Section 113 of the National Consumer Credit Protection Act requires the credit guide to give information about any indirect remuneration the licensee or its representatives are likely to receive from credit providers, a reasonable estimate of the amounts or range, and how they are worked out. The guide must also name up to six credit providers the licensee conducts business with.
What does the Privacy Act expect of a brokerage that holds a pre-approval file?
APP 11.1 requires an APP entity to take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Part IIIC requires notification of eligible data breaches. A client's borrowing capacity, savings and family plans are personal information the brokerage has to protect, wherever the draft is written.
Is a conditional pre-approval binding on the lender?
The terms are the lender's, and the email only reports them. This email's own caveat says the approval is conditional, is not an offer of credit and can be withdrawn if circumstances change. A broker should explain the conditions accurately, because clients make offers on the strength of the message and the best interests duty covers the assistance given.

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