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. - 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- For Fannie Mae and Freddie Mac loans we do not set minimum loan amounts.
- 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.
- 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.
- In reviewing appraisals, we watch for subjective terms that may be discriminatory.
- 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.
- 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.
- We train our loan personnel in the principles of fair processing and underwriting.
- 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.
- 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.
- We do not, on a prohibited basis, treat a borrower differently in servicing a loan or invoking default remedies.
- 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.
- 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.
- 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.
- 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.
- 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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