Fair Lending Policy

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 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 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 make sure that our scoring system is empirically derived and statistically sound and uses no prohibited basis other than age as a predictive factor.
  6. We train our loan personnel in the principles of fair processing and underwriting.
  7. 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.
  8. 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.