Fair Lending

QUINTESSENTIAL MORTGAGE GROUP, LLC NMLS #979226 FAIR LENDING PLAN

INTRODUCTION

Quintessential Mortgage Group, LLC (QUINTESSENTIAL) is committed to providing mortgage loan finance services to applicants and borrowers on an equal basis. It is QUINTESSENTIAL’s policy to treat all of its applicants and borrowers consistently and in compliance with Fair Lending Laws, throughout the loan process, from application to closing, including post-closing, as applicable.

QUINTESSENTIAL offer assistance and services in a fair and consistent manner during all transactions with all potential applicants and borrowers without regard to race, color, religion, national origin, sex, marital status, disability, familial status, age, receipt of public assistance, or the exercise of legal rights under the federal Consumer Credit Protection Act (15 U.S.C. §§ 1601 et seq.)

QUINTESSENTIAL is committed to implementing policies that ensure compliance with all fair lending laws, including New York Executive Law § 296-a.

FAIR LENDING OVERVIEW
The legal aspects of fair lending are contained in several federal and state laws. The purpose of these laws is to ensure that fair and equal treatment is provided to individuals seeking financing.
The Federal Equal Credit Opportunity Act (ECOA) (15 U.S.C. §§ 1691 et seq.) and it’s implementing regulation, Regulation B (12 C.F.R. Part 202), prohibit discrimination in any aspect of a credit transaction. The prohibited bases of discrimination under the ECOA are the following: race; religion; national origin; sex; marital status; age; the applicant’s receipt of income through a public assistance program; and the good faith exercise of the applicant of a right under the federal Consumer Credit Protection Act (15 U.S.C. §§ 1601 et seq.).

Various state laws also govern fair lending, including New York Executive Law § 296-a, which makes it an unlawful discriminatory practice for any creditor to discriminate on the basis of race, creed, color, national origin, age, sex, marital status, disability, sexual orientation, or military status; to use any form of application for credit or use or make any record or inquiry which expresses, directly or indirectly, any limitation, specification, or discrimination as to a prohibited basis; to make any inquiry of an applicant concerning his or her capacity to reproduce, or his or her use or advocacy of any form of birth control or family planning; to refuse to consider sources of an applicant’s income or to subject an applicant’s income to discounting, in whole or in part, because of a prohibited basis or childbearing potential; or to discriminate against a married person because such person neither uses nor is known by the surname of his or her spouse.

STRUCTURAL ORGANIZATION
QUINTESSENTIAL ’s commitment to fair lending is reflected in its belief in the shared responsibility for compliance with fair lending laws at every level of the organization. Management is responsible for approving, adopting, and implementing the Fair Lending Plan.

QUINTESSENTIAL ’s Management is responsible for ensuring that QUINTESSENTIAL ’s business practices comply with its Fair Lending Plan in the following ways: (i) communicating QUINTESSENTIAL ’s fair lending policies to the applicable business unit management; (ii) allocating, on an ongoing basis, sufficient resources to ensure the successful implementation of this Plan; (iii) obtaining input and guidance from the Compliance Department on significant business decisions that have potential fair lending impact; and (iv) Monitoring results and recommending corrective action where necessary.

Our Managing Member/Compliance Officer implements the policies outlined in this Plan in the following ways: (i) monitoring implementation of and adherence to the fair lending policies and procedures; (ii) reviewing and addressing fair lending complaints; (iii) monitoring, as appropriate, QUINTESSENTIAL ’s loan application and processing as well as its pricing policies to the extent that as applicable under law as a mortgage broker; (iv) reviewing, on a regular basis, the Fair Lending Plan to determine that it still accurately reflects the procedures followed by QUINTESSENTIAL and conforms to federal and state law; (v) maintaining training materials to keep current with changes in the law, regulation, and judicial interpretation; and (vi) providing, at least semi-annually, updates on fair lending issues to all QUINTESSENTIAL employees involved in the loan origination and loan processing.

QUINTESSENTIAL has no affiliated third party providers. If a relationship were to form in the future it would require all third party providers to have written agreements with QUINTESSENTIAL that they acknowledge their responsibility to comply with Executive Law 296-a and the policy and procedures contained in the plan.

TRAINING
QUINTESSENTIAL provides appropriate Fair Lending training for all new and future employees including senior management and other key personnel. All new employees will receive a copy of this Plan during. Training for all employees will correctly and adequately describe the the standards of Fair Lending compliance under the Equal Credit Opportunity Act, Regulation B, and applicable state laws. All participants will certify that they understand and commit to upholding the principles of Executive Law 296-a and the policy and procedures connected with the plan.

MARKETING
The Managing Member/Compliance Officer will review and must approve, prior to distribution, all marketing strategies directed to any protected class applicants or minority communities to ensure compliance with Fair Lending Laws. The Compliance Department also periodically reviews such existing marketing strategies to confirm that they remain in compliance with Fair Lending Laws.

FAIR LENDING POLICY AND LOAN PROCESS
QUINTESSENTIAL is aware that the risk of unfair lending practices runs throughout the loan process. QUINTESSENTIAL is committed to implementing training and policies that protect against discriminatory practices at every level of the loan process, from application to loan closing, and post-closing as applicable, and to taking immediate corrective action should fair lending discrimination occur. If fair lending deficiencies are observed or appear in an employee’s job evaluation, the employee will receive additional training or counseling in an effort to correct the deficiency. If the deficiency persists, the employee will be subject to more severe action, including termination.

PROCESSING AND PRICING
Processing guidelines are established through written policy and procedure in order to promote and ensure consistency throughout all classes of applicants. The guidelines address all aspects of the loan processing, including collateral standards, credit, income, source of funds, debt ratios, income documentation and other factors relevant to the loan processing. In connection with the third party lenders with whom we arrange mortgage loans, QUINTESSENTIAL will offer borrowers the available products for which the borrower would qualify based on his/her creditworthiness, ability to repay, document income and combined loan-to-value. QUINTESSENTIAL will submit all loan applications to indepedent third party lenders responsible for making the credit decision.

QUINTESSENTIAL will disclose the Lender’s credit decision to each mortgage applicant, respectively. The Lender’s disposition may include but is not limited to that factors that contributed to the approval or denial of the application, and the conditions under which a commitment is made. Loan applications that are rejected by QUINTESSENTIAL’s third party Lenders are referred to management for a second review to determine whether such application should be resubmitted to Lender for a final review.

PROMT RESPONSE TO CONSUMERS
QUINTESSENTIAL ’s policies include prompt response to consumer inquiries, concerns, and complaints in a timely, fair, and consistent manner. Complaints of violations of Executive Law 296-a will be addressed immediately by upper management and not the initial reviewer. QUINTESSENTIAL is committed to equitable treatment to all applicants.

MONITORING LOAN ORIGINATORS
QUINTESSENTIAL ’s commitment to complying with Fair Lending Laws extends to its relationships with originators. QUINTESSENTIAL will require loan Originators employed by QUINTESSENTIAL to comply with all applicable law, including all applicable federal and state Fair Lending Laws. QUINTESSENTIAL’s loan originators must agree to comply with QUINTESSENTIAL ’s Fair Lending Policies.
QUINTESSENTIAL complies Federal Equal Credit Opportunity Act, and employs business practices that promote fair lending and will not tolerate discrimination relative to borrower race, color, religion, sex, handicap, familial status, age, national origin or ancestry. QUINTESSENTIAL will not condone discrimination in any manner, in connection witih any application or credit transaction. QUINTESSENTIAL will also post a copy of this Plan on its website.

MONITORING PERSONEL
QUINTESSENTIAL will implement monitoring processes that review the loan related practices of the institution as a whole, as well as individuals within the company. QUINTESSENTIAL’s monitoring program will focus on detecting deficiencies and ensuring that QUINTESSENTIAL ’s personnel understand and perform their duties and responsibilities under this plan.

The Managing Member/Compliance Officer will perform regular audits of loan files to monitor data integrity for funded and non-funded loans. QUINTESSENTIAL will review withdrawn applications and declined applications will undergo a timely review by the Managing Member or outside, independent third party review.

ADDITIONAL INFORMATION 
If you have any questions regarding this Fair Lending Plan please contact:
David Linn
47 Mamaroneck Avenue
White Plains, NY 10601
dlinn@qmgllc.com