Disclosures

Equal Housing Opportunity Lender

We conduct business in accordance with the Federal Fair Housing Law (Fair Housing Amendments Act of 1988). It is illegal to discriminate against any person because of race, color, religion, sex, handicap, familial status, or national origin:

1. In the sale or rental of housing
2. In advertising the sale or rental of housing
3. In the financing of housing
4. In the provision of real estate brokerage service
5. In the appraisal of housing
6. Blockbusting is also illegal

Anyone who feels he or she has been discriminated against may file a complaint of housing discrimination: 1.800.669.9777 (toll free), or 1.800.927.9275 (tdd), U.S. Department of Housing and Urban Development Assistant Secretary for Fair Housing and Equal Opportunity, Washington DC 20410.

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Declaration of Fair Lending Principles and Practices

CORPORATE VISION
At Homecomings, our vision is to be the best at helping customers realize their homeownership dreams.

SOCIAL RESPONSIBILITY / COMMUNITY INVOLVEMENT
As a nationwide mortgage lender, we are committed to increasing affordable housing opportunities and addressing obstacles that face today's homebuyers, by providing products and programs that help bring home ownership to those who are under served. We also make contributions to local community causes with an emphasis on those in which our employees are involved.

FAIR LENDING ADVANCEMENT
Homecomings is committed to the principle of providing access to mortgage credit for all people, regardless of race, color, religion, national origin, age (provided the applicant has the capacity to enter into a binding contract), sex, handicap, familial or marital status, the exercise of any right under the Consumer Credit Protection Act or the fact that all or part of the applicant's income derives from any public assistance program, and regardless of where the applicant resides, will reside, or where the residential property to be mortgaged is located. Consistent with these principles, Homecomings markets its loan products nationwide.

It is Homecomings's policy and expectation that every loan applicant will first be considered for conforming conventional loan programs or government loan programs, where available, unless the applicant requests consideration of other programs. In addition an alternative loan product may be offered or recommended based upon the applicant's credit history and the interest rate desired, as well as the terms and conditions of the loan. Homecomings may engage in advertising campaigns or targeted solicitations with respect to alternative loans.

In addition to maintaining compliance with applicable fair housing laws and regulations, Homecomings is committed to taking a leadership role in the lending community, by supporting affordable housing programs which benefit our communities and contribute towards helping people finance their home ownership dreams. We realize that participating in such programs not only benefits society as a whole but contributes to the continued viability and financial well being of Homecomings.

Homecomings is committed to maintaining a work environment that is free from discrimination and encourages fair lending.

FAIR LENDING AND HOUSING INITIATIVES AND COMMUNITY OUTREACH
In order to promote home ownership, lenders must reach out to members of the communities they serve with information about the home buying process. In this regard, Homecomings:

1. Seeks to develop productive relationships, including participation in housing fairs with non-profit housing groups, counseling organizations and other community organizations.
2. Conducts and participates in seminars for consumers, real estate brokers, mortgage brokers and other individuals and organizations in order to increase home ownership opportunities.
3. Assists its affiliated banking institution (GMAC Bank) in meeting its Community Reinvestment Act goals.
4. Participates when economically feasible in public and private affordable housing and loan guarantee programs, such as those offered by the Federal Housing Administration (FHA) and State Housing Finance Agencies, in order to increase market share among under served populations.
5. Assists in the development and promotion of affordable housing loan programs and products.
6. Supports financial literacy and other education programs.

LENDING STANDARDS
Recognizing the central role of underwriting and appraisal standards in the mortgage lending process, Homecomings promotes the flexible use of these standards. To ensure that standards are applied as reasonably as possible, Homecomings keeps abreast of the discretion provided to primary lenders under the guidelines developed by Fannie Mae, Freddie Mac, the FHA, the Department of Veterans Affairs, conduits and private mortgage insurers (third parties).

An element of judgment and subjectivity enters into all underwriting decisions. To give the widest possible latitude to good judgment, the underwriting guidelines are developed to be as flexible as possible.

The responsibility for reviewing these guidelines and understanding their application to a changing population belongs to both the third parties that develop the guidelines and the primary lenders that apply them.

In applying underwriting and appraisal standards, Homecomings:

1. Actively works with secondary market investors, including government sponsored enterprises and private mortgage insurers, in eliminating unnecessarily restrictive underwriting practices and criteria;
2. Provides sufficient training to personnel to ensure that all customers will receive equal treatment in compliance with all federal, state and local fair housing and equal opportunity laws; and
3. Notifies all loan correspondents of the Fair Lending Principles and Practices of Homecomings.

SERVICING
Homecomings understands that fair lending does not end with the approval or denial of a loan. Rather, the Fair Lending laws and regulations apply to every facet of a loan, from the taking of an application to receipt of the last loan payment. Homecomings seeks to ensure that every customer is treated equally through every phase of their credit transaction, including loan servicing.

SELF MONITORING EFFORTS
Homecomings undertakes the following self-monitoring activities and corrective efforts:

1. Periodically reminds all employees that adherence to the Fair Housing Act, Equal Credit Opportunity Act and Home Mortgage Disclosure Act is essential, and that no acts of discrimination by any employee will be tolerated;
2. Adopts reliable audit and control systems to ensure fair lending compliance, including analysis of HMDA related data;
3. Performs quality control reviews of selected declined loan files during on-site branch audits to ensure that the denial was adequately supported and the related HMDA data is accurate.
4. Performs quality control reviews of its servicing unit to ensure that foreclosure and collection procedures are complied with in a non-discriminatory manner.
5. Reviews compliance procedures suggested by fair lending reviews or audits performed by HUD or other external agencies for purposes of company implementation;
6. Investigates and responds to any discrimination complaint in a timely manner; and
7. Adopts an operating philosophy and manages its business so that problems are responded to quickly. Homecomings commits to modifying any practice that it determines to have a potentially discriminatory effect and, where appropriate, provide for necessary personnel training.

EVALUATION AND REVIEW
Recognizing the need to examine its actions in achieving its goals, the management of Homecomings assesses the company's performance on a periodic basis. The evaluation covers the practices described herein and addresses any recommendations for future action.

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Patriot Disclosure Act

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OBTAINING A MORTGAGE LOAN
To help us prevent fraud and to assist the government in fighting the funding of terrorism and money laundering activities, we are obtaining, verifying, and recording information that identifies each person who obtains a mortgage loan with us.

What this means for you: When you obtain a mortgage loan, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents. 

Home Equity

Home equity financing through Homecomings is subject to your submission of a formal loan application and approval, and is not available in all states. Home Equity Lender Closing Costs apply to owner-occupied single-family residential properties only. Homecomings will waive the cost of the appraisal fee, notary fees, lender title insurance, escrow/closing fees, and recording the Home Equity mortgage. Borrower is responsible for all other costs, for example, mortgage tax, state stamps, association fee, property taxes, hazard insurance and property insurance where they apply. The Annual Percentage Rate (APR) for a line of credit is variable and may change daily. $30,000 example based on 300 monthly payments of $219.27 with 7.375% APR, assuming a FICO of 720 or above for loans where the credit line equals 80% or less of the home's equity value. APR is for illustrative purposes only. Your APR will be based on the rate set forth in your Home Equity Credit Line Agreement. The maximum APR is 18.5% or the maximum rate allowed by law, whichever is less. Consumer closing costs could average between $500 and $1,000. The Annual Fee is $35 in AL, AK, AZ, CA, CO, CT, DE, GA, ID, IN, MA, MN, MS, NE, NH, NM, NV, OR, UT and WA and $25 in FL. $20 in IL. $15 in IA. $12 in LA. The Annual Fee in OH is the lesser of $35 or 1/2% of the available credit on the date the annual fee is charged to your account. In AL title insurance is required on all lines. In all other states title insurance is required for lines over $200,000. Property insurance is required. Other Home Equity Credit Line programs are available. Offer subject to approval. AL and MS loans require an initial minimum draw of $2000 and subsequent advances of $250; KY loans require an initial minimum draw of $15,100 and subsequent advances of $500; WI loans require an initial minimum draw of $1000 if the initial credit limit is $25,000 or less ($1000 if the credit limit is $25,000 or more and subsequent advances of $250). For all other states the initial and subsequent draw(s) is $250. Please call for more information or to apply.