Fair Lending Policy

HMCO, LLC – Fair Lending Plan

1. Fair Lending Policy

HMCO, LLC (“HMCO”) is fully committed to providing credit products to all qualified applicants in compliance with the Fair Housing Act (FHAct), Equal Credit Opportunity Act (ECOA), Civil Rights Act of 1866, Truth in Lending Act (TILA) / Regulation Z, Home Mortgage Disclosure Act (HMDA) / Regulation C, Dodd-Frank Act, and New York Executive Law Section 296-a. HMCO applies consistent terms and conditions in lending and does not discriminate based on race, color, sex, religion, age, national origin, disability, marital or familial status, receipt of public assistance, sexual orientation, gender identity, military status, the good faith exercise of rights under the Consumer Credit Protection Act, birth control, or childbearing potential. HMCO encourages all qualified applicants to submit applications and ensures that no applicant is discouraged based on any prohibited factor.

All consumers are treated fairly, consistently, and in full compliance with fair lending laws. HMCO employees provide equal service, necessary assistance, and ongoing guidance to all applicants. This commitment extends to all aspects of HMCO operations, including product design, sales and marketing, loan origination, underwriting, servicing, collection, foreclosure, and secondary market activities.

Types of Discrimination

HMCO recognizes three forms of discrimination:

• Overt Discrimination: Explicit policies or expressed preferences that discriminate against a protected class, even if not acted upon.

• Disparate Treatment: Subtle or direct differential treatment of applicants in any part of the credit process based on prohibited factors.

• Disparate Impact: Policies or practices applied uniformly to all applicants that disproportionately affect a protected class, even without intent to discriminate.

All HMCO employees are trained to understand these distinctions to ensure all credit decisions are equitable.

Advertising and Marketing

HMCO provides financial services to all segments of the market consistent with safe and sound lending practices. All advertising, communications, and marketing initiatives reflect HMCO’s nondiscriminatory policies. Marketing campaigns are reviewed and approved by the Compliance Officer prior to distribution and periodically evaluated for compliance with Section 296-a. HMCO does not target marketing based on protected class or minority status.

Prohibited marketing practices include, but are not limited to:

• Limiting geographic areas based on demographics

• Using only English in areas with predominantly non-English-speaking populations

• Excluding media or channels based on demographic considerations

• Using images or messaging that exclude any protected class

Organizational Responsibility

The Compliance Officer oversees HMCO’s fair lending program, but responsibility for success rests with the entire organization. Fair lending principles apply across all operations, including product design, sales, performance evaluation, loan origination, processing, underwriting, servicing, and collection. HMCO’s organizational structure, employee training, technology, accountability measures, and ongoing monitoring demonstrate its commitment to fair lending. The CEO, Executive Management team, and Board of Directors (or designated Board Committee) ensure organizational practices reflect this commitment and that all employees understand and follow these policies.

HMCO is dedicated to delivering superior service through professionalism, teamwork, and integrity. Fair and equitable treatment of all clients remains HMCO’s primary focus as we continuously enhance our fair lending practices.

2. Employee Training

HMCO ensures all new and current employees, including senior management and key personnel, receive comprehensive education on federal and state fair lending laws, including ECOA, FHAct, TILA, HMDA, Dodd-Frank, and New York Executive Law 296-a.

Training includes:

• Annual Fair Lending Training: Instruction on applicable laws, regulations, and HMCO policies and procedures.

• Training Materials: Presentations and quizzes reinforce understanding of fair lending concepts, including overt discrimination, disparate treatment, and disparate impact.

• Acknowledgement of Completion: Employees certify that they have completed training and agree to comply with HMCO policies.

• Educational Resources: Comprehensive brochures detailing laws, regulations, and regulatory agencies are distributed at least semi-annually.

Training occurs periodically, with semi-annual updates on changes and emerging issues. Compliance personnel administer training. Management participates in conferences, webinars, and seminars to remain current on fair lending and consumer credit regulations.

3. Monitoring the Loan Approval Process

HMCO notifies applicants of lending decisions—favorable, adverse, or incomplete—within 30 days of receiving a completed application, retaining records for at least 5 years. For adverse actions, HMCO provides a Notice of Adverse Action including creditor information, nature of action, and either the specific reason for denial or notice that the reason may be requested within 60 days. This complies with ECOA, Regulation B, and FHAct requirements.

Loan denials and withdrawn applications are reviewed by senior management prior to formal denial. HMCO does not maintain affiliated lenders and discloses how commitments are approved and any conditions.

Key Practices to Ensure Fairness

• Annual Fair Lending Review: Examination of all credit policies and procedures.

• Independent File Review: Targeted review of approved and declined applications; inappropriate declines are reevaluated.

• Second Review of Denials: All declined first mortgage applications are reviewed by a more experienced underwriter.

Complaint Management

Applicants can submit complaints via HMCO’s online portal. Complaints are directed to the Chief Compliance Officer, who oversees resolution. Procedures include:

• Immediate acknowledgement and referral to senior compliance staff

• Investigation and documentation of complaints

• Written responses to applicants and, if applicable, regulatory authorities

• Corrective actions where necessary, including:

  • Offering credit to improperly denied applicants

  • Revising contributing policies or procedures

  • Training or disciplining employees

  • Enhancing oversight systems to prevent recurrence

HMCO complies with HMDA and Regulation C. Employees involved in residential mortgage lending are trained to collect HMDA-reportable information, and the HMDA Officer ensures accurate reporting.

4. Fair Pricing Initiatives

HMCO ensures all loans are priced fairly and consistently. Loan officers cannot deviate from published par rates; adjustments are handled exclusively by the secondary desk. Deviations may be approved based on objective factors, including:

• Loan-to-value ratio, debt-to-income ratio, credit score, and loan type

• Borrower relationship and history with HMCO

• Loan complexity or unique characteristics

• Market competitiveness and alternatives available

• Potential referrals or repeat business

• Borrower-specific needs, marketing and processing costs, and loan/officer performance

• Prevailing market conditions and business considerations

All pricing decisions are equitable, without regard to race, color, religion, national origin, gender, sexual orientation, age, disability, marital or familial status, military status, receipt of public assistance, or exercise of rights under the CPCA.

For non-conforming loans, if the borrower qualifies for a conventional loan, HMCO discloses this and documents it in the loan file.

Loan officers may not close high-cost loans, loans not in the borrower’s best interest, or loans they do not believe the borrower can repay. Steering borrowers to inappropriate loans is prohibited.

Procedures to Ensure Fair Pricing

• Monitoring loan pricing for compliance

• Testing loans to ensure HOEPA thresholds are not exceeded

• Oversight meetings with production channels, senior management, and the Corporate Fair Lending Officer

• Weekly Fair Lending Team meetings to review complaints, training, plan progress, and data trends

5. Third-Party Loan Originators

All third-party loan originators execute written agreements acknowledging responsibility to comply with Section 296-a. Agreements are recertified annually. HMCO monitors third-party activity by:

• Testing loan files for compliance with fair lending laws

• Including all third-party originator loans in HMCO’s annual HMDA Fair Lending Regression Analysis

6. Compliance Officer

The Compliance Officer implements HMCO’s Fair Lending Policy, conducts employee training, and monitors compliance. Responsibilities include:

• Policy Oversight: Periodic review of applications, approvals, and loan portfolio to ensure nondiscriminatory credit decisions.

• Reporting: Provide updates to CEO and Board of Directors (or designated Board Committee) quarterly and immediately if significant issues arise.

• Monitoring Compliance: Ensure loan officers follow pricing and lending policies; violations may result in disciplinary action or termination.

• Training & Materials: Maintain up-to-date materials reflecting legal and regulatory changes and provide semi-annual updates to staff.

7. Monitoring & Continuous Improvement

HMCO actively monitors adherence to Fair Lending Policies, including:

• Mortgage application and underwriting processe

• Pricing policies

• Employee responsibilities in carrying out fair lending duties

Policies and procedures are periodically reviewed by Senior Management and the Compliance Officer to remain current and aligned with regulatory requirements. HMCO commits to continuous improvement, taking affirmative steps to:

• Identify and correct disparities

• Adjust procedures and policies

• Ensure fair lending principles are consistently applied across all lending lines and operations

8. Senior Management Approval

The CEO of HMCO, LLC has approved this Fair Lending Policy as reasonably designed to ensure fair, equitable, and nondiscriminatory access to credit for both individuals and communities, and to achieve HMCO Management’s ongoing compliance with all applicable laws, regulations, rules, and guidelines.

Management’s Last Policy Review: January 7, 2026