POLICY NAME: Home Repair Selection and Loan Origination APPROVED DATE: REVISION NUMBER: REVISED DATE:

Scope: The policy handbook contains a collection of guidelines that apply to Home Repair selection and for all Wichita Habitat for Humanity employees and designated volunteers within the Home Repair Program team, including selection, support, and committee personnel. Wichita Habitat for Humanity intends that the Policy will be reviewed at least annually and updated from time to time as necessary to keep up with changes in applicable laws and changes in Wichita Habitat for Humanity’s operations. Purpose: The policies and procedures outlined in this handbook consist of key processes in Home Repair Selection/Mortgage Origination. They set out established principles and practices to guide affiliates in lawfully selecting qualified applicants who may have work completed on their home that is financed — in whole or in part — by the affiliate. The consistent application of these policies is necessary to enable compliance with applicable laws and protect the integrity of the Habitat organization. Policy: Wichita Habitat for Humanity (hereinafter referred to as “Habitat” in the policy documents) commits to complying with every policy and regulation identified in this document. If an exception is required, the board or a board designate must make the final decision. Acronyms/Definitions: AMI Area median income AML Anti-money laundering CD Closing disclosure DTI Debt-to-income ECOA Equal Credit Opportunity Act E-SIGN Act Electronic Signatures in Global and National Commerce Act FCRA Fair Credit Reporting Act FMV Fair market value GFE Good faith estimate GLBA Gramm-Leach-Bliley Act GSA Geographic service area HFHI Habitat for Humanity International HQS Housing Quality Standards

INOI Informational Notice of Incompleteness LE Loan estimate NMLS Nationwide Multistate Licensing System NOI Notice of Incompleteness NPI Non-personal information PII Personal identifiable information QLO Qualified Loan Originator RESPA Real Estate Settlement Procedures Act SAFE Secure and Fair Enforcement for Mortgage Licensing Act SSN Social Security Number TILA Truth in Lending Act TRID TILA/RESPA Integrated Disclosure Rule UDAAP Unfair, deceptive or abusive acts or practices

HOME REPAIR PROGRAM TEAM

Habitat is committed to being a responsible loan originator organization. In order to meet operational objectives, Home Repair services team members will be provided with the required training and development to perform their job in an efficient and compliant manner. Protecting financial information collected from applicants is paramount. We will operate in a manner that safeguards consumer information.

HOME REPAIR SELECTION TEAM QUALIFICATIONS The Federal SAFE Act and Truth in Lending Act (TILA) require individuals performing loan originator activities to meet certain qualification requirements. These “loan originator” activities are defined in the SAFE Act and the Truth in Lending Act (TILA)/Regulation Z. Under the SAFE Act, a originator is as an individual who: 1. Takes a residential mortgage loan application. 2. Offers or negotiates terms of a residential mortgage loan for compensation or gain.

Under TILA, a loan originator is a person who, in expectation of some compensation or other monetary gain, performs any of the following activities: 1. Taking an application for purchase money mortgage or repair loan secured by real property 2. Arranging a credit transaction 3. Assisting a consumer in applying for credit 4. Offering or negotiating credit terms 5. Making an extension of credit 6. Referring a consumer to a loan originator or creditor

Page 2 of 15

7. Advertising or communicating to the public that you can or will perform any loan origination services

Activities in the Home Repair selection process that do not constitute “loan originator” activities: 1. Performing solely clerical or administrative tasks 2. Front desk staff who just accept applications without discussion 3. Committee members who only review documents 4. Only receives, collects, and distributes information common for the processing or underwriting (ability to pay) of a loan 5. Only communicates with a consumer to obtain information necessary for the processing or underwriting (ability to pay) of a residential loan (The communication must not include offering, negotiating, or counseling consumers about residential mortgage loan rates or terms.) 6. Solely underwrites loan (number crunching)

Each member of the team identified as a loan originator must become qualified. At minimum, an individual who participates in taking an application or who assists an applicant in applying for credit MUST become a Qualified Loan Originator, or QLO.

The State of Kansas has given Habitat for Humanity Affiliates a SAFE Act exemption and thus licensing through the NMLS is not required. However, each individual loan originator must become qualified pursuant to the TILA Loan Originator Qualification requirements for individuals:

1. At the time of hire, individuals must consent to a nationwide criminal background check and credit report and must provide information regarding any military, civil, criminal, or administrative decisions. 2. The nationwide criminal background report will be screened for the presence of these disqualifiers: a. Convictions (including no-contest pleas) to any felony during the past seven (7) years b. Any felony involving fraud, dishonesty, breach of trust, or money laundering at any time 3. The credit report will be screened for patterns of financial abuse, with the following issues considered: a. The existence of current outstanding judgments, tax liens, or other government liens b. Nonpayment of child support c. A pattern of bankruptcies, foreclosures or delinquent accounts 4. Once qualified, TILA does not require ongoing background and credit checks on loan originators unless the Habitat leadership has reasonable grounds to believe the loan originator has engaged in conduct that would render him or her unsuitable to perform the activities of a loan originator according to the original qualification criteria. 5. Ensure initial and annual Training is provided to individual loan originators on both federal and state laws pertinent to the types of loans originated. The ABA Loan Originator curriculum (12 courses), meets the federal law training requirement. State law

Page 3 of 15

training may be obtained from a vendor approved to deliver SAFE Act training, or by a person/entity with the requisite experience in applicable state laws. 6. Oversight for this process will be managed by the organizational advancement director.

Training At minimum, other personnel involved in Home Repair services will complete annual training on Anti-Money Laundering, or AML; Privacy; Unfair, Deceptive or Abusive Acts or Practices, or UDAAP; and the Fair Housing Act.

Confidentiality/privacy Information collected from applicants and their household members is private and will be shared only with authorized people. Each applicant will be provided an initial privacy disclosure that will accurately reflect Habitat’s privacy policies and practices in compliance with the Gramm Leach Bliley Act, or GLBA.

HOMEOWNER RECRUITMENT

Application outreach Habitat will market throughout the geographic service area, or GSA, to recruit qualified applicants.

A. We will recruit prospective homeowners and accept applications on a rolling basis throughout the year. B. Applications are available in the office, on the website, and in the ReStore. C. Applications will be distributed at the office, community events and repair evaluation meetings. D. We are committed to upholding the spirit and requirements of the Fair Housing Act by: a. Displaying the “Equal Housing Opportunity” logo on all applications, advertisements and marketing materials, and on our website, emails, and letterhead. b. Displaying an Equal Housing Lender poster whenever applicants are met or wherever applications are taken. c. Ensuring all potential applicants have equal access to the Habitat Home Repair program by refraining from statements that would discourage an applicant.

Marketing materials A. Applications, marketing, or informational materials will not contain any reference to interest rates, down payment amounts, or loan amounts. B. Advertising across all media will be clear and accurate, will not mislead consumers or show a preference, and will not discourage any consumer.

Nondiscrimination Habitat commits to treating all applicants in an equal manner. The following attributes will NOT factor into any action for the Habitat Home Repair program, including information-sharing, distributing applications, advertising or evaluating applications: race, color, national origin, religion, sex, familial or marital status, disability, sexual orientation, age (provided the applicant

Page 4 of 15

can legally enter into a contract), income derived from public assistance, or a consumer who has, in good faith, exercised any right under the federal Consumer Credit Protection Act. To fulfill grant requirements, we may target consumers who are elderly or who have a disability, but we will not limit housing solutions to people with these characteristics.

HABITAT HOME REPAIR APPLICATION (ECOA PHASE) DEFINED Habitat will provide an application package to each consumer who requests one during the application period. The application will serve to evaluate one’s qualification for the Habitat Home Repair program based on three criteria: need, ability to pay, and willingness to partner. Application materials will not include any reference to property value or a loan amount.

Application package Documents included in the application package:  Cover letter, including income limits and application instructions  Home repair application  ECOA (Equal Credit Opportunity Act) Special Purpose Credit Program Notice  Initial privacy notice  E-Sign Act Disclosure  Borrower’s authorization

Completed application defined A “completed application” must include:

 A completed application, signed by all applicants  Proof of citizenship or legal residency for all applicants  Proof of identification for all household members  Income documents  Signed ECOA Special Purpose Credit Program Notice  Signed E-Sign Act Disclosure  Signed borrower’s authorization  Minimum HQS Assessment  A “willingness to partner” assessment

Allowable fees Habitat will collect only a fee that is reasonable to cover the bona fide cost of a credit report and application processing before receiving the borrower’s acknowledged intent to proceed.

APPLICATION EVALUATION

As a special purpose credit program, Habitat will evaluate each application to determine qualifications for “need for repairs,” “willingness to partner,” and “ability to pay.”

Nondiscrimination Habitat will not discriminate against any applicant during the credit transaction on the basis of race, color, religion, national origin, sex, marital status, age; for being a public assistance program participant; or for exercising any right under the Consumer Credit Protection Act. Upon

Page 5 of 15

Habitat’s receipt of each application, the following actions will be taken by a designated individual:

A. Date and time of submission will be noted on the application. B. An initial review will determine if the application is completed and signed. a. If not, the application will be referred to the QLO to issue the applicable notice to the applicant. b. If household income requirements based on the U.S. Department of Housing and Urban Development, or HUD, income guideline for Habitat’s area median income, or AMI; GSA affiliation; or legal U.S. residency is not met, the application will be referred to the QLO to issue an adverse action notice within 30 calendar days of receipt. c. If it is determined that the application requires more information from Habitat in order to complete the assessment, it will be referred to the QLO to issue an adverse action notice or a notice of incompleteness, or NOI, that identifies outstanding items within 30 calendar days of receipt.

Application status update Applicants will be updated on their application status every 30 days by way of a written or verbal notice from the QLO.

A. Applicants who have been issued an NOI will not receive a status update until the requested items are returned to Habitat. If the applicant does not return the items within the prescribed time frame, the application will be marked “Incomplete” and denied. B. Applicants who have been issued an Informational Notice of Incompleteness will receive a status update if the time frame to provide a decision exceeds 45 days.

Completed application All completed applications, as defined by Habitat policy in the homeowner assessment phase, will be provided with a notice of action taken within 30 calendar days of the decision:

A. Approved applicants will be provided with a partnership agreement. B. Applicants who are denied will be provided with an adverse action notice.

Excess applicants If the number of identified applicants exceeds the availability of funds, applicants will be ranked in order of first come first served. To fulfill grant requirements, we may target consumers who meet one of the grant required characteristics.

Declined applicants A denial may be issued at any time before closing. Applications declined for any reason will immediately be issued an adverse action notice pursuant to current legal and policy requirements.

General selection criteria In accordance with Habitat selection policies, all applicants will be evaluated on the criteria below:

Page 6 of 15

A. Need for repairs a. This will be based on a whole house assessment using Minimum Housing Quality Standards B. Willingness to partner a. There will be a minimum of 4 hours of sweat equity. Additional hours based on size of the project. b. There will be a financial education course required for all partner families C. Financial readiness/ability to pay

Record Retention All applications will be retained for 25 months from the date the applicant was notified of the decision. This file will retain all information used to evaluate the applicant, along with a copy of the notice of action taken.

Residency A. Habitat encourages all interested consumers to apply for its housing programs regardless of their current address. B. Habitat will not restrict its program to U.S. citizens and permanent residents; however, at least one person to be listed on the lien as a grantee for a Home Repair loan, and financially responsible as a signer of the mortgage or loan documents, must be either a documented United States Citizen or a legal permanent resident (the “Permanent Owner”). a. Individuals must provide documentary proof of a status sufficient to demonstrate they are able to meet the requirements to be deemed an eligible lien holder by Habitat. Acceptable documentation includes, but not limited to, one or more of the following: i. U.S. Passport ii. Certificate of Naturalization iii. Permanent Resident Card (I-551) iv. Birth Certificate with valid photo identification

Marital Status Habitat does not discriminate in its selection process on the basis of marital status. However, there are legal issues that make information regarding the marital status of applicants relevant to the application process.

Habitat will only inquire of marital status using the terms “married,” “unmarried,” and “separated.” The term “unmarried” includes single, divorced, and widowed individuals. In the State of Kansas, marital rights become relevant with a mortgage, even if only one party of the married couple is applying for the mortgage. Even if separated, if the marital estate is not yet settled, any repairs (or funds used to make such repairs) could be considered marital property and may be subject to division by the court. Therefore, Habitat requires that the spouse of an applicant must be included as a co-applicant on the application, as he/she is entitled to a portion of the property; this safeguards Habitat’s security interest in the loans and grants we provide. As a result, Habitat is unable to accept applications from individuals who are separated and unwilling to have both parties on the application and mortgage.

Page 7 of 15

Habitat requires documentation of marital status at the time of application.

Financial evaluation The financial evaluation will include:

A. Income limits B. AMI C. Household income D. Cost-burden analysis

Physical living condition evaluation This evaluation will include an analysis of the following and a home visit:

A. Serious health challenges: a. Carbon monoxide b. Pest infestation c. Presence of lead, mold, radon d. Allergens for those affected B. House does not meet minimum HQS

Willingness to partner An applicant’s willingness to partner is a critical component of our relationship. Applicants to Habitat’s Home Repair program will evidence a “willingness to partner” by agreeing to meet all the obligations outlined in the current partnership agreement. Failure to meet those agreements in the time frames identified will result in de-selection/denial from the program.

Ability to pay Ability to pay assessment will be performed to ensure that each applicant is financially able to meet their obligation for the Home Repair Program.

Income A. Employment income: a. Full- and part-time employment will be verified with the current employer. b. Part-time employment and seasonal income can be used if the employer verifies that employment has continued uninterrupted for the past two years, and is likely to continue. c. Overtime, bonus, and commission income will be included if the employer states that it is more than likely to continue into the future. d. Self-employed income will be used if the applicant has been self-employed for a full two (2) years. The usable income for a loan is the bottom line on the federal tax return after all deductions. Depreciation and depletion will be added back to income. A current profit-and-loss statement will be required for review. B. Other income considerations: a. Only income received by the mortgagor(s) will be used for debt service and mortgage calculations to determine ability to pay.

Page 8 of 15

b. Child support and alimony will be used. Acceptable proofs of payment are 12 months of cancelled checks or a printout from the court if it is being paid through the court system. c. Public assistance income will be verified and used if it is reasonably expected to continue. No applicant will be excluded solely because he or she receives public assistance. d. All other income used must be ongoing for the next three (3) years.

Assets Assets are defined as cash or non-cash items that can be converted to cash, including real property, savings, stocks, bonds, and other forms of capital investment. Household assets will be verified and actual income generated from assets within a 12-month period will be included in annual income. Income over $5,000 will be calculated using the HUD guidelines for calculating imputed income at the current Passbook Rate. Actual value will be counted if under $5,000.

Debt-to-income ratio The standard Housing Expense-to-income ratio will be capped at 30%. Allowable exceptions are defined in the debt-to-income ratio exceptions section below.

Debt included in Housing Expense-to-income ratios: A. Principle B. Interest C. Property taxes D. Insurance E. Utility allowance F. New Home Repair loan

The standard Debt-to-income ratio will be capped at 43%. Allowable exceptions are defined in the debt-to-income ratio exceptions section below.

Debt included in debt-to-income ratios: A. All installment debt B. Minimum payments on all open accounts with a balance owing C. Co-signed loans D. Child support E. Alimony F. Joint debt with previous marriage will be included unless divorce papers clearly define that the liability belongs to the ex-spouse and there is proof of 12 months of payments made by the other partner. G. Deferred student loans will be included, using a monthly payment of 1 percent of the balance. Other repayment amounts (e.g. income-based repayment (IBR) plan) will be used in lieu of the 1 percent of balance if proper documentation is provided. Habitat understands that applicants and co-applicants who are still in school cannot apply for consolidation or IBR, however, with appropriate documentation of federal student loans Habitat will utilize the IBR calculator (http://www.ibrinfo.org/calculator.php) to estimate

Page 9 of 15

the payment that will be due when the applicant or co-applicant graduates and include that amount as a monthly recurring debt payment. H. Collections will be included, using a monthly payment of 5 percent of the balance. I. Medical debt.

Debt-to-income ratio exceptions 33/45% - Requires one (1) of the following Compensating Factors:  Verified/ documented cash reserves equal to or exceeding 3 total monthly mortgage payments.  Minimal increase in housing payment: new total monthly housing payment doesn’t exceed current monthly housing payment by more than $100 or 5% (whichever is less); AND there is a documented 12-month housing payment history with no more than one 30-day late payment. 37/47% - Requires two (2) of the following Compensating Factors:  Verified/ documented cash reserves equal to or exceeding 6 total monthly mortgage payments.  Minimal increase in housing payment: new total monthly housing payment doesn’t exceed current monthly housing payment by more than $100 or 5% (whichever is less); AND there is a documented 12-month housing payment history with no more than one 30-day late payment.  The credit report shows established credit lines in the borrower’s name, open for at least 6 months; AND the borrower can document the accounts have been paid off in full monthly for at least the past 3 months. 40/50% - Little to no discretionary debt:  The borrower’s housing payment is the only open account with an outstanding balance not paid off monthly; AND the credit report shows established credit lines in the borrower’s name open for at least 6 months; AND the borrower can document these accounts have been paid off in full for at least the past 3 months.  Significant Additional Income (overtime, bonuses, part-time or seasonal employment) not reflected in Effective Income – received for at least 1 year and will likely continue; AND if it were included in gross effective income, is sufficient to reduce the qualifying ratios to not more than 37/47%. Credit A. A residential mortgage credit report, also known as a tri-merge credit report, will be obtained and reviewed to determine creditworthiness. B. No foreclosures within last 3 years. The 3-year period begins on the date in which title transferred from the owner (applicant). If the credit report does not indicate the date of foreclosure, applicant must provide a copy of the Settlement Statement. Exceptions to the 3-year period may be evaluated based on extenuating circumstances. C. No applicant will be approved with an active bankruptcy.

Page 10 of 15

o Chapter 7 Bankruptcy: Exceptions to the 2-year period may be evaluated based on the borrower’s disregard for financial obligations, the borrower’s inability to manage debt and extenuating circumstances. D. Garnishment does not disqualify a program participant. Situations may be considered if, when garnishment is included in income calculation, DTI is still within program guidelines including garnishment. Additional documentation of garnishment timeline may be required. E. No more than one 30-day late mortgage payment in a 12-month period. Payment must be current at time of application. Exceptions may be evaluated for extenuating circumstances. F. At least 6 months of timely payments on modifications. G. All open trades must be current. Habitat will consider if they have written arrangements made for repayment with creditor before closing. H. Repossessions must be at least 12 months old at time of closing. Homeowner not denied if a balance remains after 12-months prior to applicant approval and if not impacting lien position. o Situations may be evaluated if 1 months of payment as tied into other credit/ debt management organization’s Debt Management Plan. Include payment in DTI. Payments have been made satisfactorily and on time I. Collections cannot exceed $2000.00 J. Charge offs have to be a year or older. K. All liens and judgements must be satisfied prior to program approval o Tax lien may be considered “satisfied” if HO has entered into a valid repayment plan and timely payments have been made for at least 3 months. Any required payments must be included in monthly DTI calculation. Requires documentation from the IRS of the agreed upon payment plan. L. There can be no more than six (6) credit report inquiries within the past six (6) months for possible debts, other than mortgage, housing, utility, insurance and auto loans. When multiple creditors have pulled the applicants’ credit for one application for credit, the associated inquiries will count as one (1). M. Twenty-five percent (25%) or less of the total trades can be delinquent (defined as unpaid collections that do not have a current written payment arrangement, past due balances on open trades, or more than three (3) late payments on an open trade in the past year).

Mortgage/loan calculations A. Thirty percent (30%) of gross income can go to housing (principle, interest, taxes, insurance, plus a predetermined utility allowance) (maximum front-end ratio). B. No more than 43% of an applicant’s gross income can go to housing plus other debt (maximum back-end ratio) at closing.

(Please see exceptions above under debt to income ratio)

PARTNERSHIP

Habitat will serve the household on a first come first served basis. To fulfill grant requirements, we may target consumers who meet one of the grant required characteristics.

Page 11 of 15

De-selection Home repair program participants will be de-selected only in the following cases: A. Demonstrated fraud on the application. a. Fraud or misrepresentation on the application undermines the integrity and fairness of the selection process, which is wholly dependent upon access to complete and accurate information from each applicant household. Each applicant household’s obligation to provide complete and accurate information extends to the entire application process. This includes completion of the online pre-application, paper application, as well as an obligation to respond honestly and completely to subsequent inquiries from Habitat or Home Repair Program Committee members. b. Examples of fraud or misrepresentation include, but are not limited to: i. Supplying inflated income information ii. Omitting debt information on the application iii. Supplying inaccurate information about household size or composition iv. Falsifying or misrepresenting other information c. Fraud or misrepresentation constitute grounds for de-selection regardless of what point in the process they are discovered. d. After selection, a Partner Family’s obligation to be honest and forthright with Habitat continues. Misrepresentations regarding the completion of Sweat Equity hours or other Partner Family obligations under our partnership constitute both fraud and a failure to partner. Suspected misrepresentations of Sweat Equity will be addressed according to the same procedures outlined in this section. e. A Partner Family that is de-selected for fraud or misrepresentation is not eligible to reapply at a later date. B. Failure to complete requirements set forth in the partnership agreement and sweat equity agreement letter— i.e., lack of willingness to partner. a. Circumstances under which a Partner Family may be found to have failed to partner include, but are not limited to, the following: i. Failure to comply with the terms of the signed Partnership Agreement; ii. Failure to complete the minimum hours of Sweat Equity iii. Each Partner Family’s commitment to work the required amount of Sweat Equity in accordance with established policies and procedures is at the heart of the partnership with Habitat. Habitat will make every reasonable effort to assist families through the Sweat Equity process. iv. If a Partner Family does not meet the minimum obligations in a timely manner it risks being de-selected for failure to partner. b. A Partner Family de-selected for failure to partner will be eligible to reapply one (1) year following notification of de-selection. C. Negative change in financial condition that significantly affects the ability to pay. a. Negative change in economic circumstances can set the Partner Family up for failure by placing them in a situation they may not be able to afford. It is the policy of Habitat, however, to work with the Partner Family to the fullest possible extent that is reasonable. De-selection on this ground is a last resort.

Page 12 of 15

b. Other changes in the family (i.e. size) should not be considered as reason for deselection so long as the family’s household income remains in line with the guidelines set in this Policy. c. The Partner Family must notify Habitat of any such change in economic circumstances within thirty (30) days of the change. d. A Partner Family de-selected for a change in financial circumstances will be eligible to apply one (1) year following notification of de-selection. D. Self De-Selection by Partner Family a. A Partner Family may choose to de-select themselves from the program for personal reasons. b. This notice should be provided to Habitat in writing whenever possible or verified and documented by a Home Repair Program representative. c. A Partner Family who self-de-selects will eligible to reapply six (6) months following notification of de-selection.

Adverse action If a prospective Home Repair client is de-selected, Habitat will send the applicant an adverse action notice that includes the reason for the denial or de-selection.

Sweat equity A. Each prospective homeowner and their household members (as applicable) will contribute sweat equity hours toward the completion of their home repair project. These hours will be completed on the schedule as defined in the partnership agreement and will include volunteerism, training for basic home maintenance, homeowner financial training, and other activities as defined by the partnership agreement. Failure to complete these hours is cause for de-selection. B. Sweat-equity has no monetary value and will not be compensated should an applicant withdraw or be de-selected.

Electronic communication Habitat will provide the option of communicating electronically with each applicant.

A. Applicants electing to receive electronic communications will acknowledge an E-Sign Disclosure. B. All personally identifiable information will be sent through encrypted email.

Affordability A fully amortized mortgage loan will be granted to qualified applicants who meet the conditions in their partnership agreement.

A. All loans will not exceed a 15-year term. B. A determination of each applicant’s affordability index will be completed to ensure that their DTI does not exceed 43% of gross income. C. At closing, each applicant’s loan or mortgage payment plus existing housing costs will not exceed 30 percent of their gross income.

Page 13 of 15

(Please see exceptions above under debt to income ratio.)

Subsidy Habitat may provide a subsidy in the form of a forgivable loan based on income and availability. A. The subsidy given will require a deferred lien on the property. B. The term of the lien will be 5 years. C. All liens will be forgiven at a rate of 20% per year for 5 years as long as the ownership remains the same. D. Early payment in full of the primary loan or mortgage will not satisfy the terms of the forgivable loan and lien.

Closing costs A. Repair client is responsible for closing costs. The client will have the option to finance these costs. a. Financed closing costs will be factored into the 30 percent front-end ratio to ensure affordability.

PREPARATION (RESPA PHASE) AND CLOSING

Habitat will ensure practices for all mortgages and loan closing and their preparation will adhere to applicable federal and state laws. Homebuyers will be provided all relevant information describing the repairs and financing.

Mortgage application/final evaluation A. When a mortgage application as defined by RESPA is triggered, Habitat will: a. Within three (3) business days, mail or email (as applicable) the initial disclosures to the borrower. b. Set an appointment to meet with the borrower to review the disclosures. c. Perform final underwriting and validations. d. Coordinate with funding partners, if applicable. B. Upon receipt of the intent to proceed from the borrower, Habitat will: a. Prepare closing disclosures and conveyance documents. b. Set a closing date and coordinate with the settlement agent. c. Request a copy of the insurance binder from the buyer. C. Scheduling a final walkthrough with the Home Repair team and the Homeowner: a. Complete the punch list walkthrough no later than one (1) week before closing. D. Preparing the warranty binder for the borrower: a. Included in the binder will be all warranty information and instruction manuals, as applicable. E. Upon preparation of closing documents: a. Review disclosures for accuracy. Be mindful of tolerances. b. Provide closing documents to the borrower no later than three (3) business days before closing. A business day excludes Sunday and public holidays.

Page 14 of 15

Prohibited practices A. Habitat will not give or accept any fee, kickback, or item of value in connection with a real estate settlement service. B. Habitat will not require, directly or indirectly, that the buyer purchase title insurance from any particular title company.

Record retention Habitat will safeguard applicant information as follows: A. All applicant information will be stored in a locked fireproof cabinet in the Habitat office. Only affiliate personnel with authorization to read or review such information can remove the file. Neither the file nor any file contents are permitted to be removed from the affiliate office. B. Applications and all information used to determine qualification will be retained for 25 months after a decision has been made. C. Habitat or the assigned title company will provide the original, recorded lien to the homeowner once returned from the real estate records. At closing, Habitat will maintain, and the homeowner will receive, a duplicate original or copy of all other documents executed at the closing or loan signing.

Closing A. Closings are supervised by licensed closing officers and assistants who are licensed or otherwise qualified to conduct residential real estate closings in the state in accordance with all applicable laws and industry standards. B. All applicable documents will be sent to the settlement agent. C. If changed circumstances have been identified that warrant a re-disclosure of the LE or GFE/TIL Statement, it will be provided within three (3) business days of the identification of the change. D. Closing will be set for any time after the seventh day the initial disclosures were provided.

______Responsible Staff –Signature and Title Printed Name Date

______Board Representative-Signature Printed Name Date

Page 15 of 15