Fair Lending Policy

POLICY. It is Merchants Bank’s policy to treat all consumers consistently and fairly and in compliance with Fair Lending laws.

APPLICATION OF POLICY. Merchants Bank recognizes that affirmative steps must be taken to ensure that this Policy is applied consistently and continuously through all aspects of its lending operations, including product design, marketing and advertising, and the application and underwriting processes. Merchants Bank will regularly monitor its lending activity for compliance with this Policy. Where our review suggests a deviation from the Policy may have occurred, Merchants Bank will act expeditiously to investigate, and if necessary, institute corrective measures.

EMPLOYEES. Merchants Bank employees will offer assistance and services in a fair, equitable and consistent manner during performance of their jobs. We communicate our Fair Lending policy to all of our employees and hold them accountable for treating all consumers consistently and fairly.

THIRD PARTIES. Merchants Bank will require all contracts with mortgage brokers to contain a provision that the broker will comply with all Fair Lending laws. Merchants Bank will post a copy of this Fair Lending Policy on all of its websites including Broker, correspondent and consumer sites.

UNDERWRITING. Merchants Bank is dedicated to making credit decisions on the basis of sound underwriting practices without consideration of an applicant’s race, color, religion, national origin, sex, marital status, familial status, age, receipt of income from public assistance, disability (“Prohibited Basis”),  or to the fact that the applicant has in good faith exercised any right under the Consumer Credit Protection Act.

MARKETING. Merchants Bank will not use any marketing tactics or materials that discriminate based upon a Prohibited Basis.

PRICING. Merchants Bank will not consider a Prohibited Basis in the pricing of its lending products.

COMPLAINT RESOLUTION. Any written complaint received alleging discrimination on a Prohibited Basis shall be forwarded, as per the Bank’s Customer Compliant Policy, to the Chief Credit Officer (CCO) of Merchants Bank who will then forward to the appropriate department head or the Bank’s legal counsel as appropriate.