FAIR LENDING POLICY

It is our policy to comply with the Equal Credit Opportunity Act and the Fair Housing Act. In addition, it is our policy to comply with state laws that provide greater protection. International City Mortgage, Inc. DBA Doorway Home Loans (Hereinafter referred to as Doorway) does not discriminate against any applicant on the basis of race; color; religion; creed; national origin; ancestry; sex; marital status; familial status (number and age of children); sexual orientation; age (provided that the applicant has the capacity to enter into a binding agreement); medical history; disability; physical condition; military status; because the applicant has in good faith exercised any right under the Consumer Credit Protection Act or the Service members Civil Relief Act (SCRA); that all or part of a consumer's income derives from a public assistance program; or any other basis prohibited by law.

At Doorway, we do not discriminate against any applicant or discourage anyone on a prohibited basis from submitting an application. To assure that our employees have a clear and unequivocal statement of our commitment to a nondiscriminatory method of doing business, we have adopted the following fair lending policy. Employees must be thoroughly familiar with this policy and follow it.

1. We do not discriminate against a loan applicant or borrower on the basis of race, color, religion, national origin, sexual orientation, handicap, age, the fact that all or part of an applicant’s income comes from any public assistance program or because the applicant has exercised any right under any relevant state or federal law.

2. We do not selectively encourage applicants and we take no action that would, on a prohibited basis, discourage a reasonable person from applying for a mortgage loan.

3. We do not, on a prohibited basis, refuse to make a loan, vary the terms offered including the amount, interest rate, period or type of loan, or use different standards to evaluate collateral or decide whether to extend credit.

4. We avoid practices or policies that have a discriminatory effect. This rule applies to all phases of our mortgage lending business. It applies even though we do not intend the policy or practice to be discriminatory and even if the policy or practice appears to be neutral.

5. We have adopted nondiscriminatory loan underwriting standards that avoid subjective, unwritten rules that can have a discriminatory effect. We make these underwriting standards public upon request at each of our offices.

6. We make sure that our scoring system is empirically derived and statistically sound and uses no prohibited basis other than age as a predictive factor.

7. We train our loan personnel in the principles of fair processing and underwriting.

8. Our Quality Control Manager regularly reviews both our loan underwriting standards and the business practices by which we implement them to determine whether they ensure equal lending opportunity and reports to management.

9. We periodically review our loan portfolio and applications to make sure that we are serving the community adequately and on a nondiscriminatory basis in light of the community’s demographic characteristics and credit demands.

10. We conspicuously display the poster in a public area of each of our facilities stating that we are ascribing to the Equal Housing Act. Additionally, on all forms of advertisements, regardless of media, we include the Equal Housing Opportunity logo and/or the Equal Housing Opportunity slogan.