Fairness in Lending

FAIR & RESPONSIBLE LENDING POLICY
First Metropolitan Financial Services Lending Value

Purpose

It is First Metropolitan’s policy to treat you with professionalism, courtesy and fairness. Our employees strive to offer assistance, encouragement and service in a fair, equitable and consistent manner. The success of the Fair & Responsible Lending Policy (the “Policy”) is the responsibility of the entire organization. This Policy applies across all aspects of lending operations, including advertising and marketing, loan origination, processing, underwriting, closing, and loss mitigation activities.

First Metropolitan’s commitment to fair and responsible lending principles is demonstrated throughout the Company’s structure and organization, in employee accountability, through various monitoring and auditing programs and in education and training programs it offers. First Metropolitan’s management team is responsible for establishing policies to ensure that operations and business practices reflect our strong commitment to fair and responsible lending, and that all employees are aware of that commitment.

Policy Statement

First Metropolitan has adopted the Policy to promote compliance with all applicable state and federal laws ensuring fair lending and equal access to credit, including but not limited to the federal Equal Credit Opportunity Act (“ECOA”) and the Federal Reserve Board’s Regulation B (which implements ECOA). The Policy is also adopted to prevent unlawful discriminatory practices in relation to its lending activities.

First Metropolitan will not discriminate with respect to any aspect of a credit decision on the basis of race, color, religion, national origin, sex, marital status, disability, age (provided that an applicant has the capacity to enter into a binding contract), receipt of income from any public assistance program, sexual orientation, the good faith exercise of any rights under the federal Consumer Credit Protection Act, or the good faith exercise of rights under any state law allowing or recognizing Registered Domestic Partnerships, Civil Unions, or other such similar unions or partnerships regardless of the title assigned to them. First Metropolitan is fully committed to the principle that all decisions related to the granting or servicing of credit should be made with consideration of safe and sound business practices. First Metropolitan takes appropriate steps to ensure that this Policy is applied consistently and continuously through all aspects of its credit operations, including advertising and marketing, loan origination, processing, underwriting, closing, and loss mitigation activities.

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