FireBreak Pillar

01 Purpose

Define the minimum FireBreak Pillar scope that lets Lendistry Home Loans track a Disaster Recovery Mortgage Solutions (DRMS) borrower's progress toward IBHS Wildfire Prepared Home Plus compliance, staged against a rebuild loan, using the existing case/assessment/mitigation/verification model rather than new architecture.^[1]

02 Background

The existing domain model already covers most of this pilot's mechanics, unmodified:^[2]

What's left to do

1. Load the 29-item IBHS checklist into a DemonstrationProfile — content authoring against already-structured data, not schema work.
2. Confirm the reviewer role for this pilot (§6.1).
3. A minimal Lendistry-facing view or export format for the completion record, delivered via PartnerOutboxEvent.
4. A case-intake path for a Lendistry-side (or admin, on their behalf) user to create a case referencing a DRMS loan.

No changes to the equal-weighted, non-actuarial scoring approach are required — DRMS profile scoring follows the same demonstration-only convention as the rest of the product.^[2]

03 Users, roles & jobs-to-be-done

No new roles are required — but the rollout needs more than a role label per user. Each persona below is a distinct job, so the case UI and any compliance-facing export can be scoped to what each actually has to accomplish.

3.1  Lender-side (lender_admin / lender_reader)

A DRMS loan touches at least three distinct lender-side jobs, each with a different relationship to the case data:

• Construction-Loan Draw Officer — needs per-property mitigation status visible alongside standard draw-progress inspection. Status must be advisory input, not a disbursement gate. Also needs a portfolio-level rollup, not per-case drill-down.
• Compliance/Risk Officer — needs a hashed, exportable audit trail covering full rejection/correction history, not just terminal state, for BofA/CCF portfolio reviews. Implies a dedicated compliance-export view (§4.6), distinct from the day-to-day case UI.
• Loan Officer — needs plain-language deficiency reasons surfaced to them, not raw finding/action internals, so they can field borrower questions without escalating to the reviewer.

lender_admin maps to the Draw Officer and Compliance/Risk Officer; lender_reader maps to the Loan Officer — existing views need a portfolio-rollup mode and a compliance-export view added, not new roles.^[4]

3.3  FireBreak Pillar-side (deepening existing roles)

• homeowner — the displaced DRMS borrower. This persona is displaced and under stress by definition. Needs a plain-language status vocabulary (never raw internal state names) and rejection framing that makes clear a gap is about the work, not the homeowner.
• contractor — needs acceptance criteria and required shot types stated up front, not discovered via rejection: draw-inspection rework is typically borrower-billed, so an avoidable rejection is a direct homeowner cost.
• reviewer — needs (1) locked capture metadata (timestamp/geolocation) on evidence, flagged when absent, mirroring how insurance/construction photo review already guards against reused or pre-work photos; (2) rejection reasons from a controlled list mapped to specific IBHS Plus requirements, for cross-reviewer consistency.
• pillar_admin — operates the rollout, authors the IBHS profile, manages onboarding.

04 Core user flows

4.1  Case creation

A lender_admin (or pillar_admin on their behalf) creates a Case with lender_org_id and loan_reference set to Lendistry's loan ID. Homeowner and contractor are added via case membership. Where a lead originates from FireBreak's own outbound pipeline rather than Lendistry's interest form, this is the hand-off point from the Origination & Underwriting appendix §2.6.

4.2  Initial gap assessment

An assessment run against the pinned IBHS Plus profile version produces findings per requirement category. Non-compliant findings generate mitigation actions with required evidence and acceptance criteria.

4.3  Mitigation work & evidence

Contractors are assigned per-action or case-wide. Action status moves required → in_progress → submitted as evidence is filed. A reviewer accepts (terminal) or rejects (reason required, reworkable).

4.4  Verification & lender-facing output

Once all in-scope actions are accepted, a verification snapshot is created — immutable once written — and a hashed, versioned completion record is generated, suitable for the loan file. A partner-outbox event carries the status/completion event to whatever endpoint Lendistry designates.

4.5  Interim status visibility

Because DRMS loans are construction loans that may disburse in draws, Lendistry-side users should see interim status (e.g. "3 of 7 actions accepted"), not just the terminal verified state — via the existing status model: not_ready → mitigation_in_progress → reinspection_pending → gap_remaining → verified.^[4]

4.6  Compliance export view — for the Compliance/Risk Officer

A dedicated view exporting a case's full history for capital-partner portfolio review: every mitigation-action status transition including rejections and resubmissions, every evidence-submission revision with capture metadata, and the verification snapshot / completion-record hash where reached. Representable from existing, mostly append-only or immutable tables — a read/export view, not a new write path.

05 Out of scope

• Issuing or replacing the actual IBHS designation.
• Any actuarial or financing-benefit computation.
• A bespoke Lendistry LOS/servicing integration beyond a generic outbound webhook — build the generic mechanism; defer bespoke API work until Lendistry names a target system.
• Multi-peril support.
• Public-facing homeowner self-registration — case creation is lender/admin-initiated, consistent with the lender-first model.
• Any insurer integration or discount-eligibility claim (§3.2).

06 Open questions requiring Lendistry engagement

6.1  Reviewer assignment

The evidence-review UI supports any reviewer role — Lendistry staff, an insurer partner, or an IBHS inspector. Reviewer assignment is a role value, configurable per case without a schema change.

6.2  Case-creation trigger

At what point in Lendistry's process (pre-approval, post-closing, first construction draw) tracking should start, and whether interim status needs to gate draws or the terminal record is sufficient, are configuration decisions to make with Lendistry.

6.3  IBHS Plus requirement line items

The technical standard (current edition: December 2025, effective 1 Jun 2026) and IBHS's applicant-facing How-To checklist are structured into a 29-item checklist with measurements, referenced test standards, and evidence types — ready to seed a demonstration profile directly.

6.4  Data-sharing and liability boundaries

Given BofA/CCF capital involvement and Lendistry's CDFI status, an agreement should clarify early: what borrower data FireBreak Pillar can access/retain, and how non-certification disclaimers surface to Lendistry's stakeholders.

07 Success criteria

01 Summary

The Lendistry pilot scopes FireBreak Pillar as a lender-initiated mitigation-tracking layer: Lendistry opens a case for a borrower it already has. This document scopes a different, upstream capability: FireBreak originates its own pipeline of rebuild candidates directly from the destroyed-homes universe, pre-qualifies them financially and logistically, and then routes qualified homeowners toward a lending partner.

This is possible because FireBreak/00start has direct, structured knowledge of the Palisades and Eaton fire burn scars: destroyed-structure geodata identifying every destroyed structure, plus property-attribute and comps data at scale, and the domain expertise to estimate total rebuild cost per destroyed property.

02 Market opportunity

2.1  The addressable universe is known and finite

Unlike a typical lead-generation problem, the addressable population here is not "somewhere out there" — it is a bounded, geocodable set: every structure recorded as destroyed in the Palisades and Eaton fires. At the 18-month mark, ~1% of Eaton Fire homes were rebuilt and effectively none in the Palisades, alongside 2,981 permits issued and 1,796 homes under construction (see Pilot MRD §2.1).^[1] The overwhelming majority of the ~16,000-structure universe is still pre-financing, pre-contractor, pre-plan.

2.2  Homeowners are underinformed about their own numbers

Population-level shortfall reporting^[2] describes a pattern, not what any individual homeowner knows about their own property. A displaced homeowner typically lacks a defensible rebuild-cost estimate tied to their specific lot, a clear picture of how that compares to their insurance payout, or a concrete next step toward financing — a real information gap FireBreak's data assets are positioned to fill.

2.3  Existing rebuild-support programs are pull, not push

The programs referenced in the Pilot MRD (ALI Gap Rebuild, CalAssist Mortgage Fund, the state's $100M fund, Lendistry's own DRMS interest form)^[3] are all inbound: a homeowner has to already know the program exists and take the first step. No public evidence was found of an outbound, property-specific, data-driven program reaching destroyed-home owners directly with a rebuild-financing offer — that's the gap Phase 1 targets. (A fuller read on how fast this white space may close is in Internal Notes.)

03 Target customer / beneficiary

• The homeowner — a displaced Palisades/Eaton fire survivor who has not yet secured rebuild financing. FireBreak's outbound contact is the first touch; FireBreak Pillar's pre-qualification and compliance/underwriting support is the ongoing relationship.
• The lending partner — receives pre-qualified, informed, warm-referred borrowers instead of cold interest-form submissions. Additive to, not a replacement for, Lendistry's own interest-form channel.

04 Problem statement

1. No party is yet reaching the ~16,000-structure destroyed-home universe with a rebuild-financing offer informed by property-specific data. The gap is property-specific, data-informed origination specifically, not outbound origination in general.
2. Homeowners lack an early, defensible estimate of their own rebuild cost and financing need, a prerequisite to knowing whether programs like Lendistry's DRMS are worth pursuing.
3. Lenders have no visibility into which destroyed properties are good candidates before homeowners self-select into an interest form.
4. There is no financial tracking layer for the inbound query itself — nothing today tracks the financial components of an inquiry as a first-class, auditable record tied to the eventual case.

05 Solution direction

• Phase 1 — Pipeline generation & financial pre-qualification. A purpose-built harvest system over the destroyed-home universe, enriched with rebuild-relevant property attributes. Score/segment properties for outbound-marketing candidacy. Track the financial components of every inbound query from first contact.
• Phase 2 — Plan/budget compliance review. Evaluate submitted plans/budgets against the IBHS checklist before construction, surfacing gaps early and refining the rebuild-cost estimate.
• Phase 3 — Mitigation-compliance layer for construction tracking. Extend compliance tracking through the rebuild, alongside whichever draw-management platform Lendistry uses rather than replacing it.

Full detail in the Origination PRD tab.

06 Risks & open questions

1. Outbound contact to fire survivors requires unusual care. A vulnerable, high-stress population. Messaging/tone, timing, and opt-out handling need review before any send.
2. Rebuild-cost estimates are FireBreak's own model, not a third-party verified figure. Always labeled as an estimate — never a loan approval or an appraisal.
3. Data provenance and freshness. Destroyed-home status, permit activity, and comps all change over time; stale data used for outbound contact or cost estimation is a real accuracy risk.
4. Regulatory exposure of outbound solicitation. Mortgage-solicitation, fair-lending, or CAN-SPAM/TCPA-adjacent rules depending on channel — a question for counsel before Phase 1 execution.
5. Lender exclusivity. Whether this is Lendistry-exclusive or multi-lender from the start affects positioning language in any homeowner-facing materials.

01 Purpose

Define a phased build for FireBreak-originated wildfire-rebuild pipeline generation and pre-qualification, upstream of the Lendistry (or any lending partner's) case-intake process.

02 Phase 1 — Pipeline & pre-qual buildable now

2.1  Data foundation

A new harvest system, purpose-built for this module. Two data layers: (1) a destroyed-structure identity layer — coordinates and identifying data for every destroyed structure, plus damage-inspection photos where available; (2) a property-attribute / comps layer — square footage, year built, lot size, prior sale history, comparable nearby listings/sales. Both key on property identity and carry an explicit freshness timestamp per record.

2.2  Candidate scoring for outbound marketing

A candidacy signal per property: estimated rebuild cost relative to likely insurance payout, current rebuild-activity status, and property characteristics correlating with rebuild complexity. Produces a ranked candidate list — a human reviews it before any outbound contact goes out.

2.3  Rebuild-cost estimation

A cost-per-square-foot estimation approach using the comps layer, producing a range estimate, always labeled as such, versioned by methodology, never presented as a loan approval, appraisal, or guarantee.

2.4  Inbound query financial tracking

Every inbound response gets a structured financial record from first contact: the estimate shown, homeowner-reported figures as they emerge, the computed gap, and inquiry status — trackable even for inquiries that never become a case.

2.5  Outbound channel and scope boundary

This scopes the data, scoring, and tracking system only — not creative/messaging content or send cadence. Any actual send requires tone/timing review for a displaced population, counsel review of solicitation exposure, and a human-reviewed send decision.

2.6  Hand-off to case creation

Once pre-qualified and interested, a homeowner hands off into the Pilot PRD's case-creation flow (§4.1): a Case is created with the property reference and accumulated pre-qualification data attached, keyed on the same property identity used throughout Phase 1.

03 Phase 2 — Plan/budget compliance review directional

Once a homeowner has plans and a contractor budget, evaluate those before construction starts, against the 29-item IBHS checklist (see Pilot PRD §6.3).

• Plan compliance pass — compare plans against design-time-applicable checklist items, flagging gaps before a budget is built around a non-compliant design.
• Budget compliance and completeness pass — does the budget actually price the compliance items flagged? The "quantitative surveyor" function.
• Refined cost/loan-size estimate — replace Phase 1's comps-based range with a plan/budget-grounded figure.

04 Phase 3 — Mitigation-compliance layer for construction tracking directional

Construction-draw management — draw scheduling, inspections, lien-waiver tracking, budget/covenant compliance — is an established, well-capitalized software category.^[2] Built (getbuilt.com) works with roughly 150 U.S. and Canadian construction lenders and has managed over $135B in cumulative construction value since 2015 (~$68B/year as of its most recent published figures); Rabbet and smaller players (Sekady, DrawStack) cover overlapping ground.^[2] None of them track building-code or resilience-standard compliance — their "compliance" is loan-covenant and lien-document compliance, not IBHS or any comparable mitigation standard.

Phase 3 is scoped as the mitigation-compliance layer that sits alongside or feeds into whichever draw-management platform Lendistry uses — reusing the Pilot's MitigationAction/EvidenceSubmission/ReviewDecision machinery directly^[1] for the compliance-specific tracking, rather than building a competing draw-management or spend-tracking system from scratch.

05 Out of scope — all phases

• Outbound marketing creative, messaging, and send-cadence decisions.
• Any actuarial, appraisal, or loan-approval claim.
• Insurer integration or discount-eligibility claims.
• Multi-peril support.
• Full implementation detail for Phases 2–3 — intentionally directional.

06 Open questions

1. Harvest system build vs. buy, and data licensing. MLS/listings data terms and destroyed-structure data usage terms need a dedicated review before Phase 1 data collection begins.
2. Candidacy scoring model validation. Scoring factors are hypothesized, not validated against real outcome data — treat the first cohort as a model-validation exercise.
3. Single-lender vs. multi-lender routing — affects how Phase 1's hand-off should be architected.
4. Phase 2/3 domain-model reuse boundary — Phase 3's reuse of existing tables is confirmed directionally; Phase 2 may need new domain concepts not yet designed.
5. Draw-management platform selection. Whether Lendistry has selected or is evaluating a construction-draw-management platform (Built, Rabbet, or otherwise) for DRMS is unknown and directly answerable — determines whether Phase 3 integrates with an existing system or has a larger scope to fill.^[2][3]

Lendistry's own hiring

A Lendistry job posting (Sr. Program Manager, "Project Home" disaster mortgage product, Tustin CA, req JR100045 — found and read 30 Aug 2026)^[1] describes a role targeting the same gap as our Origination & Underwriting Phase 1:

“lead borrower acquisition, pipeline development, and counseling services for Project Home's disaster mortgage product” — reporting to the VP of Programs, tasked with establishing “an ecosystem of partners including builders, funders, and HUD-Certified Counselors to engage a pipeline of 750-1,000 potential borrowers with the goal of converting 250-300 clients into borrowers during the pilot phase.”

Named mechanisms: recruiting 3-4 HUD-certified housing-counseling partners, building "a coalition of vetted construction-to-permanent (C2P) lenders," leading customer outreach, coordinating "Lendistry Customer Experience Center (CEC) integration," and "beta testing the loan application process with selected borrowers and iterating based on feedback."^[1]

What the posting does not appear to include: property-specific destroyed-home identification, comps-based rebuild-cost estimation, or DINS-level geodata. The language is about partner-network building and counseling-standard compliance, not data/analytics capability — that's our differentiation, and it's real, but it's not unopposed white space.

Timing implications

Lendistry is not passively waiting for its interest form to fill up — it's actively staffing an in-house acquisition function, with a pipeline target (750-1,000) roughly two orders of magnitude below the ~16,000-home addressable universe. This means:

• The pitch's "no party is proactively reaching this population" framing needs to stay scoped to property-specific, data-driven origination specifically — not outbound origination in general. We should never imply to Lendistry that we researched their hiring in detail; the pitch should win on our own capability evidence, not on knowledge of their internal staffing.
• Every quarter we don't engage is a quarter their in-house function has to build its own partner network and become less dependent on an external channel.
• This hire is being staffed now, for a program opening applications this fall — real timeline pressure on when to reach out.

Lendistry's construction-lending maturity

Lendistry's core business — SBA/small-business lending — is real and mature: #8 nationally in PPP volume (2021), $10.5B+ distributed to 640,000+ businesses by May 2026, and a fast climb in SBA 7(a) ranking (#87 in 2023 to #20 in 2024, per one source; company materials describe a #2 non-bank ranking by loan count — the two figures use different cuts of the data and should both be treated as approximate).^[2] None of this is construction lending.

Lendistry Home Loans (LHL) itself opened 7 Aug 2024 — confirmed via primary press across six state-launch announcements — with conventional purchase/refi, FHA, and VA IRRRL products only.^[3] No construction-lending product existed at LHL before DRMS. Public engineering-hiring signals describe LHL's business-lending platform (origination, decisioning, servicing handoff) — nothing construction-draw-specific. The "Project Home" hiring push (above) is building partner networks and counseling capacity, not technology.

Confidence: moderate-high that DRMS is genuinely new territory for Lendistry, not routed through mature in-house construction-loan infrastructure. Real gap: a third-party construction-servicing vendor or bank partner could exist that's invisible to public job postings/press — a direct, worth-asking question for Lendistry, not an assumption to bake into the pitch either way.

Construction-draw software landscape (Phase 3 context)

Phase 3 as originally scoped ("quantitative surveyor," "spend vs. budget," "draw-milestone alignment," "AI project manager") substantially overlaps with an established, well-capitalized software category, not empty market:

• Built (getbuilt.com) — $125M Series D at a $1.5B valuation (2021, led by TCV), ~150 lender customers, $135B in cumulative construction value managed since 2015 (a separate, more recent source cites ~$68B/year — figures not fully reconciled, treat both as directional).^[2] Platform covers draw management, inspections, lien-waiver tracking, payments, and budget/covenant compliance.
• Rabbet — smaller ($9.94M total raised per available data), overlapping functionality: budget-to-draw reconciliation, covenant checks, portfolio risk dashboards.
• Sekady, DrawStack — smaller, similar-category players, not researched in depth.

Critically: "compliance tracking" in all of these products means loan-covenant/lien-document compliance — not building-code or resilience-standard compliance. No evidence any of them touch wildfire hardening, IBHS, or a comparable standard, and no evidence of CDFI, disaster-recovery-lending, or California-wildfire-specific relationships at any of them. The mitigation-compliance angle is the differentiation that survives this finding — now backed by a direct negative finding (no draw-management vendor does this), not just absence-of-evidence from earlier research.