FAIR LENDING POLICY
Purpose: America’s Choice Home Loans is committed to fair lending practices and subscribes to all efforts to ensure the consistent and equitable application of our policies and programs. The goal at America’s Choice is to promote equal access to all credit products and services and will not discriminate in any aspect of a credit transaction – applications for the granting, withholding, extending, renewing of credit, or in establishing the terms of interest rates, terms or conditions of any form of credit, especially on the basis of the following:
This policy extends to our practices in all aspects of our home loan business.
All employees at America’s Choice Home Loans will be educated about our Fair Lending Policy.
1. Orientation – As part of every new employee orientation, each person will be provided a copy of our Fair Lending Policy and receive appropriate training.
2. On-going training – Employees will receive appropriate continuing training on the America’s Choice Fair Lending Policy.
Our credit application will not make inquiry, directly or indirectly, which expresses any limitation or discrimination as to any protected class. Also, the following additions will be followed:
1. It will not inquire about an applicant’s family planning matters.
2. All sources of income will be considered and not discounted based on the protected categories.
3. Will not discriminate against a married person because the applicant does not use their spouse’s surname.
4. An applicant will not be denied credit in circumstances where other applicants of like overall creditworthiness are granted credit.
5. Special requirements or conditions will not be imposed where similar conditions are not required of other applicants of like overall creditworthiness.
Monitoring the loan approval process
America’s Choice Home Loans will ensure applicants are treated fairly in the loan approval process by implementing a review and quality control process.
Underwriting guidelines are established through written policies and procedures in order to promote and ensure consistency throughout all classes of applicants. The guidelines address all aspects of the underwriting process, including collateral standards, credit, income, and sources of funds, income documentation and other factors relevant to the underwriting decision.
If an applicant does not meet underwriting standards, the applicant will be provided alternative lending options whenever possible. The underwriting guidelines are periodically reviewed to ensure they meet regulatory and credit standards changes.
Additionally, underwriting policies will consider applicants with non-traditional credit histories and we will offer help equally to all applicants who do not meet minimum underwriting guidelines. Proper documentation of such help will be established.
All marketing strategies and promotions will be conducted in a manner that does not discriminate on the aforementioned basis. Marketing plans will be reviewed according to company policy and senior level management to make certain there aren’t any discriminating practices.
Applicants who might have a complaint against us will be provided a means to direct a complaint about a possible violation of fair lending. They will be able to contact a senior company employee who will investigate the situation in a timely fashion and respond to the applicant’s concerns. All copies of these complaints will be given to senior management for quality control. Customers will also be provided with a copy of a brochure on fair lending at application.
AMERICA’S CHOICE HOME LOANS
8584 Katy Freeway, Suite 200
Houston, TX 77024