FAIR LENDING POLICY

 
We do not discriminate against any applicant or discourage anyone on a prohibited basis from making an application. To assure that our employees have a clear and unequivocal statement of our commitment to a nondiscriminatory method of doing business, we have adopted the following statement of company fair mortgage lending policy. Employees must be thoroughly familiar with this policy and follow it both in spirit and in practice.
  1. It is against this company’s policy to discriminate against a loan applicant or borrower on the prohibited basis of race, color, religion, national origin, sexual orientation, handicap, marital status, age, the fact that all or part of an applicant’s income comes from any public assistance program or because the applicant has exercised any right under the Consumer Credit Protection Act or any similar state law.
  2. We do not fail to provide information or services or provide different information or services, including credit availability, application procedures, or lending standards on a prohibited basis.
  3. We do not selectively encourage applicants and we take no action that would, on a prohibited basis, discourage a reasonable person from applying for a mortgage loan.
  4. We do not, orally or in writing, express a preference based on a prohibited factor or indicate that we will treat applicants differently on a prohibited basis.
  5. We do not, on a prohibited basis, refuse to make a loan, vary the terms offered including the amount, interest rate, period or type of loan, or use different standards to evaluate collateral or decide whether to extend credit.
  6. We do not, on a prohibited basis, treat similarly situated applicants differently, including the amount of assistance, encouragement or information we give the applicant during the application process.
  7. We do not, on a prohibited basis, discriminate because of the characteristics of a person associated with the applicant including a joint applicant, spouse, business partner, the present or prospective occupants of the property to be financed or the area where the property is located.
  8. We do not require an applicant who is individually creditworthy to provide a co-signer, even if we apply this requirement without regard to sex, marital status or any other prohibited basis.
  9. We avoid practices or policies that have a discriminatory effect. This rule applies to all phases of our mortgage lending business. It applies even though we do not intend the policy or practice to be discriminatory and even if the policy or practice appears to be neutral.
  10. For HUD loans, we do not engage in tiered pricing by providing for a variation in mortgage rate charges that exceeds two percentage points within a geographical area and we base any variation up to two points on actual variations in fees and costs to make the loan.
  11. For Fannie Mae and Freddie Mac loans we do not set minimum loan amounts.
  12. We have adopted nondiscriminatory loan underwriting standards that avoid subjective, unwritten rules that can have a discriminatory effect. We make these underwriting standards public upon request at each of our offices.
  13. If we use a credit scoring system, we make sure that it is empirically derived and statistically sound and uses no prohibited basis other than age as a predictive factor.
  14. In reviewing appraisals, we watch for subjective terms that may be discriminatory.
  15. For HUD loans, we make sure that female and minority appraisers are chosen from the HUD roster of appraisers in the same percentage as the group represents on the roster.
  16. A management committee reviews both loans about to be rejected and exceptions underwriters have made to underwriting standards to find and eliminate patterns of exceptions that might have a discriminatory effect.
  17. We train our loan personnel in the principles of fair processing and underwriting.
  18. We are committed to nondiscriminatory marketing. We affirmatively market and make credit available in low and moderate-income areas. Our marketing practices and business relationships with developers and real estate brokers do not improperly restrict our clientele and exclude disadvantaged segments of the community.
  19. To assure that real estate brokers with whom we do business are aware that we are committed to fair lending principles, the loan officer or other employees dealing with the broker for the first time on our behalf supplies him or her with a copy of our fair lending policy statement.
  20. We do not, on a prohibited basis, treat a borrower differently in servicing a loan or invoking default remedies.
  21. The Quality Control Manager or other designated person reviews our marketing and advertising practices to determine whether we make our mortgage lending services available without discrimination to the community we serve and reports to management.
  22. Before we implement a major new policy or practice we review it to determine whether it could have the effect of discriminating against applicants or borrowers.
  23. At least annually, the Quality Control Manager reviews both our loan underwriting standards and the business practices by which we implement them to determine whether they ensure equal lending opportunity and reports to management.
  24. We periodically review our loan portfolio and applications to make sure that we are serving the community adequately and on a nondiscriminatory basis in light of the community’s demographic characteristics and credit demands.
  25. We conspicuously display the poster in a public area of each of our facilities stating that we are ascribing to the Equal Housing Act. Additionally, on all forms of advertisements, regardless of media, we include the Equal Housing Opportunity logo and/or the Equal Housing Opportunity slogan.

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