Fair Lending Policy Statement

In accordance with the Fair Housing Act, the Equal Credit Opportunity Act ("ECOA"), the Civil Rights Act of 1866, and New York Executive Law Section 296-a, it is, and shall be, the policy of VanDyk Mortgage Corporation ("VanDyk") to make its credit products available, and do so on a consistent basis regarding terms or conditions on a loan, to all qualified applicants without discrimination on the basis of race, color, sex, religion, age, national origin, handicap, marital or familial status, receipt of public assistance, good faith exercise of rights under the Federal Consumer Protection Act, sexual orientation or military status. It is, and will continue to be, VanDyk's policy not to discourage the submission of an application for credit by any applicant on any of the prohibited areas listed above.

All consumers are to be treated fairly, consistently, and in compliance with fair lending laws, according to VanDyk's policy. Our employees will consistently offer fair service, any needed assistance, and continued encouragement. VanDyk will also clearly communicate our fair lending policy to all of our brokers and correspondents. These principles shall extend to purchase money financing and refinancing as well as VanDyk's collection and foreclosure practices.

VanDyk shall provide financial services to all income segments of our market that are consistent with safe and sound lending practices. The advertising of VanDyk, as well as all of its communications to the public shall be portrayed in way making it clear that VanDyk does not discriminate on a prohibited basis. VanDyk will commence specific activities to encourage a wide range of clients to approach its offices and to consider us as a financial service resource. VanDyk does not employ marketing strategies directed at protected classes or minority communities. Nevertheless, all marketing campaigns are reviewed and approved by its Compliance Officer prior to distribution to ensure that they are in compliance with federal and state fair lending laws, including New York Executive Law 296-a.

VanDyk's Compliance Officer is responsible for overseeing its fair lending plan. Nevertheless, the success of VanDyk's Fair Lending Program is the responsibility of the entire organization. VanDyk's fair lending practices apply across all aspects of our operations, including marketing, loan origination, processing, underwriting, servicing, and collection activities. Our company's structure and organization, training, technology, employee accountability, and continued monitoring and auditing of programs demonstrate VanDyk's commitment to fair lending. Our Chief Executive Officer and the Executive Management team is responsible for establishing practices designed to ensure that our operations reflect our strong commitment to fair lending and that all employees are aware of, as well as following that commitment.

At VanDyk we are dedicated to providing superior service to our clients through teamwork, admirable professionalism, and promise to action. Fair treatment of all clients is, and shall be, our primary focus as we identify ways to continue to meet our commitment to fair lending.

Employee Training

VanDyk ensures that all new and current employees, including senior management and all key personnel, are educated on the rules of fair lending, including the principles of New York Executive Law 296-a, using the following tactics:

• Training new and existing employees on an annual basis with regards to the fair lending laws, regulations, and VanDyk's fair lending policies and procedures;
• The training includes a detailed, informative PowerPoint and follow up quiz;
• All employees are required to sign an acknowledgement, certifying that they completed fair lending training and agree to uphold VanDyk's fair lending policies and procedures, including the principles of New York Executive Law 296-a; and,
• Distributing a fair lending brochure that contains extensive background on fair lending rules and government regulatory agencies to every employee in VanDyk bi-annually.

The training will be conducted periodically, with at least semi-annual updates on fair lending issues. Compliance personnel will conduct the training. Management will attend conferences, webinars, or seminars on fair lending topics in order to remain current on consumer credit and fair lending regulations.

Monitoring the Loan Approval Process

VanDyk notifies applicants of their lending decision, whether favorable, adverse, or incomplete, within 30 days after receiving a completed application and retains records for 25 months following such notification. When adverse action is taken, the Company provides a Notice of Adverse Action. This notification is in writing and contains certain information, including the name and address of the creditor and the nature of the action that was taken. VanDyk also either provides the applicant with the specific reason for the action taken or discloses that the applicant has the right to request the reason for denial within 60 days of receipt of the notification, along with the name, address, and telephone number of the person who can provide the specific reason for the adverse action.

VanDyk also adheres to ECOA's notification requirements for adverse actions and incomplete applications that do not meet borrower eligibility outlined in guidelines. Loan application denials as well as withdrawn applications are referred to management for a second review prior to formal denial by underwriter. VanDyk has no affiliated lenders and will disclose to all applicants how a commitment was approved and under what conditions a commitment is made.

To make sure our applicants are treated fairly in the loan approval process, VanDyk follows the steps listed below:

• Annually conduct a fair lending examination of all credit policies;
• An independent team of fair lending underwriters reviews the targeted files of approved and declined applications to confirm consistency in the credit decision. If one of these underwrites find an application that was inappropriately declined, then an offer of credit is made;
• Re-evaluate all declined first mortgage applications a second time by a more experienced underwriter.

VanDyk has in place a complaint portal on its main website to which applicants are directed should they have a complaint. The filing of a complaint triggers a notification to VanDyk's Chief Compliance Officer who is personally involved with all customer complaints. Complaints from applicants relating to alleged violations of Executive Law 296-a are resolved efficiently without being unduly burdensome to the applicant. If any employee of VanDyk, consumer, or a regulator refers a fair lending complaint to management or the compliance officer, the policy of the company is to take the following steps:

• VanDyk will act on oral or written complaints immediately. All complaints will be referred to the senior compliance officer.
• VanDyk will forward a letter to the customer and, if appropriate, the relevant Department of State Government acknowledging the complaint and noting that a formal response will be forthcoming.
• The compliance officer or his or her designee will thoroughly review and investigate complaints.
• The compliance officer will maintain complete documentation concerning the complaint and the results of VanDyk investigations.
• When the investigation is complete, VanDyk will send a letter to the customer and, if appropriate, to the Department, revealing the results of its investigation.
• If the situation indicates a significant error on the part VanDyk or any other error affecting the customer, an employee of VanDyk will call the customer, explain the situation, offer apologies, and request a meeting to discuss any corrective action.
• VanDyk will process each complaint fairly and consistently and within the time frames prescribed by law by the relevant state regulatory Department, or within 30 days from the date that VanDyk received the complaint from the customer or the State regulatory agency, whichever is earlier.

If any discrimination is discovered, Company will determine the cause and take appropriate corrective action. This action may include, but is not limited to, the following: Offering to extend credit to the consumer, if they were improperly denied or whose applications may have been inappropriately processed.

• Correcting any institutional policies or procedures that may have contributed to the discrimination
• Identifying, and then training and/or disciplining, the employees involved
• Improving oversight systems to ensure that there is no recurrence of the discrimination

VanDyk acts in compliance with The Home Mortgage Disclosure Act of 1975 ("HMDA"), and the implementing regulations known as Regulation C, which require financial institutions to collect, report and disclose information about their mortgage applications, originations and purchases. VanDyk employees are trained on collecting HMDA reportable information on all residential mortgage loans. VanDyk's HMDA officer ensures that loans are reported consistent with HMDA requirements.

Fair Pricing Initiatives

With respect to pricing loans, loan officers have no discretion in setting a price other than VanDyk's par rate as specified and announced by VanDyk management. Any adjustments on pricing are made through VanDyk's secondary desk. Deviations from the par rate may be approved based upon prevailing market conditions, risk factors, and unique business considerations associated with a particular loan. These include loan-to-value ratio, debt-to-income ratio, credit score, loan type, the relationship of the consumer with the company, the frequency of loan officer's requests for downward adjustments, the difficulty of the loan, any complicating or unique factors applicable to the loan, the options and alternatives for the loan, the risk that the loan will not close, competing offers (or the potential) for the consumer, the possibility of referrals and repeat business, any specific or unique needs of the borrower, the cost of marketing, procuring, originating, and processing the loan, overall business volume, loan officer's business volume, the performance record of the loans closed by the loan officer, and overall market trends. In negotiating the price on a loan, all borrowers will be treated equally without regard to race, religion, national origin, gender, sexual preference, age, disability, marriage status, and/or any other protected characteristics. For borrowers seeking non-conforming mortgage products who would otherwise meet conventional underwriting standards, VanDyk will disclose to the applicant when it has been determined that he or she meets underwriting standards that typically would qualify him or her for a conventional loan product. VanDyk shall document this disclosure in the loan file with a statement that the disclosure was given and signed by the person giving the disclosure. A loan officer may not close a high-cost loan, nor close a loan that is not in the best interest of a consumer. Loan officers may not close a loan where the loan officer lacks a good faith belief that the consumer has the ability to repay the loan. A loan officer may not steer a borrower to a loan that is not in the borrower's best interests.

In order to ensure that loans are priced fairly, VanDyk follows the following procedures:

• Monitor loan pricing for compliance with fair lending laws;
• Test loans to confirm that the pricing and fees do NOT exceed HOEPA thresholds;
• Company Oversight of Fair Lending within VanDyk, each production channel has regular fair lending meetings with senior executives with oversight responsibilities, including VanDyk's Corporate Fair Lending Officer;
• VanDyk has its own weekly fair lending team meeting to discuss the status and cause of any fair lending complaints, fair lending training efforts, progress against the fair lending plan, and data trends and analysis.

Third Party Loan Originators

VanDyk requires written agreements from all third party loan originators, which certify that they acknowledge their responsibility to comply with fair lending laws and regulations, including Executive Law Section 296-a. VanDyk requires an annual recertification from all third party loan originators regarding their compliance with fair lending laws and regulations. VanDyk will test all third party loan originator loan files for compliance with fair lending laws and regulations, including Executive Law Section 296-a. VanDyk will also include all third party loan originator loans in its HMDA Fair Lending Regression Analysis that it conducts on at least an annual basis.

Compliance Officer

VanDyk's Compliance Officer is responsible for implementing VanDyk's fair lending policy and training employees concerning the policy. The Compliance Officer is also responsible for reviewing, at least quarterly, VanDyk's underwriting standards and its implementation of those standards to determine whether they are compliant with its commitment to Fair Lending. The Compliance Officer is also responsible for periodically reviewing its loan applications and portfolio to ensure that Company is complying with this Policy and extending credit on a nondiscriminatory basis. VanDyk's Compliance Officer is also responsible for reporting findings and any issues with respect to its implementation of the fair lending policy to VanDyk's President and/or Board of Directors on a quarterly basis or whenever fair lending or pricing issues arise that, in his/her determination, need to be addressed. Loan officers should realize that VanDyk monitors pricing and that loan officers who are found to have violated this policy by considering improper criteria, not acting in VanDyk's best interests, or not acting in the best interests of the borrower will be subject to discipline and/or termination as determined in VanDyk's discretion.

Monitoring

VanDyk will monitor the implementation of and adherence to the fair lending policies and procedures. VanDyk will monitor, on an ongoing basis, the mortgage application and underwriting processes and pricing policies. VanDyk will ensure that employees understand their duties and responsibilities under the fair lending policy, and that such duties are being carried out. Fair lending policies and procedures should be periodically reviewed by Senior Management and the Compliance Officer to ensure that they remains current.