Fair Lending Policy

1. Our Commitment

A Good Lender is committed to:

• Providing equal opportunity to all loan applicants
• Making credit decisions based solely on creditworthiness and ability to repay
• Treating all applicants fairly and respectfully
• Complying with all applicable fair lending laws and regulations
• Maintaining a diverse and inclusive workplace
• Training our employees on fair lending practices
• Regularly reviewing our practices to ensure compliance

2. Federal Fair Lending Laws

We comply with all federal fair lending laws, including:

2.1 Equal Credit Opportunity Act (ECOA)

ECOA prohibits discrimination in any aspect of a credit transaction based on:

• Race or color
• Religion
• National origin
• Sex
• Marital status
• Age (provided the applicant has the capacity to contract)
• Receipt of income from any public assistance program
• Exercise of any right under the Consumer Credit Protection Act

2.2 Fair Housing Act (FHA)

FHA prohibits discrimination in housing-related transactions, including mortgage lending, based on:

• Race or color
• Religion
• National origin
• Sex
• Familial status (families with children under 18, pregnant women)
• Disability (physical or mental impairment)

2.3 Home Mortgage Disclosure Act (HMDA)

We collect and report demographic data to help regulators identify potential discriminatory lending patterns. This data collection:

• Is required by federal law
• Is used for statistical purposes only
• Does not affect your loan application
• Helps ensure fair lending practices industry-wide

2.4 Community Reinvestment Act (CRA)

We are committed to meeting the credit needs of all communities we serve, including low- and moderate-income neighborhoods.

3. California Fair Lending Laws

3.1 California Fair Employment and Housing Act (FEHA)

California law provides additional protections against discrimination based on:

• Ancestry
• Medical condition
• Genetic information
• Marital status
• Sexual orientation
• Gender identity and expression
• Source of income (including housing assistance)
• Military or veteran status

3.2 California Consumer Credit Reporting Agencies Act

We comply with California requirements for obtaining and using consumer credit reports.

3.3 California Fair Lending Notices

As required by California law, we provide:

• Notice of your right to receive a copy of your appraisal
• Disclosure of your right to request information about your credit score
• Information about how to file a complaint with the California DFPI

4. Prohibited Practices

We do not engage in any of the following discriminatory practices:

4.1 Redlining

We do not:

• Refuse to lend or set different terms based on the racial or ethnic composition of a neighborhood
• Avoid certain neighborhoods when marketing our services
• Use different standards for evaluating properties in certain areas

4.2 Steering

We do not:

• Direct applicants to certain types of loans based on their race, ethnicity, or other protected characteristics
• Discourage applicants from applying for certain loan products
• Provide different information based on protected characteristics

4.3 Disparate Treatment

We do not:

• Treat applicants differently based on protected characteristics
• Use different underwriting standards for different groups
• Charge different fees or interest rates based on prohibited factors
• Provide different levels of service to different groups

4.4 Reverse Redlining

We do not:

• Target protected groups for unfair or predatory loan products
• Market high-cost or risky loans to vulnerable populations
• Take advantage of borrowers' lack of financial sophistication

5. Credit Decisions

5.1 How We Make Credit Decisions

Our credit decisions are based solely on:

• Credit History: Payment history, credit utilization, length of credit history
• Income: Stable, verifiable income sufficient to repay the loan
• Assets: Down payment, reserves, and other assets
• Employment: Employment stability and history
• Property: Property value, condition, and intended use
• Debt-to-Income Ratio: Ability to manage monthly payments
• Loan-to-Value Ratio: Equity position in the property

5.2 What We Do NOT Consider

We do NOT consider:

• Race, color, or ethnicity
• Religion or religious practices
• National origin or immigration status (except as required for legal residency)
• Sex or gender identity
• Sexual orientation
• Marital status (except when required for joint applications)
• Age (except to determine legal capacity to contract)
• Familial status or plans to have children
• Disability (except to determine ability to manage the property)
• Receipt of public assistance
• Neighborhood characteristics unrelated to creditworthiness

5.3 Objective Criteria

All of our underwriting criteria are:

• Objective and measurable
• Applied consistently to all applicants
• Based on sound business reasons
• Reviewed regularly for potential disparate impact

6. Your Rights

6.1 Right to Equal Treatment

You have the right to:

• Be treated with respect and dignity
• Have your application considered fairly
• Receive the same terms and conditions as similarly qualified applicants
• Apply for any loan product for which you qualify

6.2 Right to Information

You have the right to:

• Know why your application was denied
• Receive a written adverse action notice if denied
• Request additional information about the credit decision
• Review and dispute inaccurate information in your credit report

6.3 Right to Privacy

You have the right to:

• Privacy of your personal and financial information
• Know how your information will be used
• Limit sharing of your information (in certain circumstances)

6.4 Right to Fair Appraisal

You have the right to:

• A fair and unbiased property appraisal
• Receive a copy of your appraisal
• Challenge an appraisal you believe is inaccurate

7. Reasonable Accommodations

7.1 Disability Accommodations

We provide reasonable accommodations for applicants with disabilities, including:

• Communication: Alternative formats for documents (large print, Braille, audio)
• Physical Access: Accessible office facilities
• Application Process: Assistance with completing applications
• Documentation: Flexibility in providing required documentation
• Meeting Locations: Alternative meeting locations if needed

7.2 How to Request Accommodation

To request a reasonable accommodation:

• Contact us at (510) 589-4096 or info@agoodlender.com
• Describe the accommodation you need
• We will work with you to provide appropriate accommodation
• Accommodations are provided at no charge

8. Training and Compliance

8.1 Employee Training

All our employees receive regular training on:

• Fair lending laws and regulations
• Prohibited discriminatory practices
• Identifying and preventing bias
• Cultural sensitivity and diversity
• Providing excellent service to all customers

8.2 Monitoring and Testing

We regularly:

• Review our lending practices for potential disparate impact
• Analyze our loan data for patterns of discrimination
• Conduct fair lending audits
• Test our advertising and marketing for compliance
• Review customer complaints for discrimination issues

8.3 Compliance Officer

We have designated a Fair Lending Compliance Officer responsible for:

• Overseeing fair lending compliance
• Investigating discrimination complaints
• Implementing corrective actions
• Training staff on fair lending requirements

9. How to File a Complaint

If you believe you have been discriminated against, you have several options:

9.1 Contact Us Directly

9.2 File a Complaint with Government Agencies

Consumer Financial Protection Bureau (CFPB)

Website: www.consumerfinance.gov/complaint/
Phone: 1-855-411-2372
TTY/TDD: 1-855-729-2372

U.S. Department of Housing and Urban Development (HUD)

Website: www.hud.gov/fairhousing
Phone: 1-800-669-9777
TTY: 1-800-927-9275

California Department of Fair Employment and Housing (DFEH)

Website: www.dfeh.ca.gov
Phone: 1-800-884-1684
TTY: 1-800-700-2320

California Department of Financial Protection and Innovation (DFPI)

Website: dfpi.ca.gov/file-a-complaint/
Phone: 1-866-275-2677

9.3 Legal Action

You also have the right to:

• Consult with an attorney
• File a lawsuit in federal or state court
• Seek damages for discrimination

Note: There are time limits for filing complaints and lawsuits. Consult with an attorney to understand your rights.

10. Anti-Retaliation Policy

We will not retaliate against you for:

• Filing a fair lending complaint
• Participating in a discrimination investigation
• Exercising your rights under fair lending laws
• Assisting others in filing complaints
• Reporting potential violations

Retaliation is prohibited by law and will not be tolerated.