Predatory Lending Policy
In an effort to comply with the predatory lending policies of the U. S. Department of Housing and Urban Development, Freddie Mac, and Fannie Mae, which have been revised effective January 1, 2001, 1st Advantage Mortgage has implemented the following guidelines effective March 19, 2001, regarding the fees charged a borrower when a mortgage is originated. These guidelines reflect 1st Advantage Mortgage commitment to promote fair lending, and are not the direct result of any one agency's policy:
Points and fees related to each mortgage should be disclosed in writing to the borrower in accordance with applicable federal and state law. For loans delivered to 1st Advantage Mortgage, the total points and fees charged a borrower should not exceed 5 percent of the loan amount.
For the purposes of this guideline, points and fees do not include:
Bona fide discount points
Pass through fees (Fees paid for actual services rendered such as property appraisals, credit reports, etc.)
Mortgage insurance
Title, hazard, and flood insurance policies
State or local transfer fees or taxes
Escrows deposits for taxes and insurance, "prepaid" items
Approved agents of 1st Advantage Mortgage should not refer or "steer" borrowers to higher-cost mortgage products nor encourage or require borrowers to select a mortgage product designed for less creditworthy borrowers. The originating lender should inform borrowers about all mortgage products that they qualify for so that borrowers may select the mortgage that best meets their housing finance needs. Borrowers who seek financing through a higher-priced subprime program offered by the originating lender, should be directed to the standard mortgage product line if the borrower qualifies for a standard product.
Approved agents of 1st Advantage Mortgage should not discriminate in any manner relative to lending practices because of a borrower's race, color, religion, sex, handicap, familial status, age, or national origin.
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