Advertising & Marketing Policy

Bay Arealty — Genesis Loans Advertising and Marketing Policy

NMLS #368880 | DRE #01447306

Effective Date

This Advertising and Marketing Policy is effective as of January 1, 2026, and applies to all employees, independent contractors, and third-party vendors acting on behalf of Bay Arealty — Genesis Loans.

Purpose

This policy outlines the guidelines and standards for the creation, publication, and distribution of all advertising and marketing materials by Bay Arealty — Genesis Loans. The purpose of this policy is to ensure that all marketing communications are truthful, transparent, non-deceptive, and fully compliant with all applicable federal and state laws and regulations governing mortgage lending and advertising.

General Principles

All advertising and marketing materials produced by or on behalf of Bay Arealty — Genesis Loans must adhere to the following principles:

• Accuracy and Truthfulness: All statements, claims, and representations in advertising materials must be accurate, truthful, and not misleading. No advertisement shall contain false, deceptive, or misleading information regarding loan products, rates, terms, fees, or any other material aspect of a mortgage transaction.
• Clarity and Transparency: All advertising materials must be clear, conspicuous, and easy to understand. Key terms, conditions, and disclosures must be presented in a manner that is readily noticeable and understandable to the intended audience. Fine print or obscured disclosures that contradict or diminish the main message are prohibited.
• Compliance with Laws: All advertising and marketing activities must comply with all applicable federal and state laws and regulations, including but not limited to:

• Truth in Lending Act (TILA) / Regulation Z: Requires specific disclosures when advertising credit terms, including Annual Percentage Rate (APR), finance charges, and payment terms. Trigger terms that require additional disclosures must be handled in accordance with TILA requirements.
• Real Estate Settlement Procedures Act (RESPA): Prohibits kickbacks and unearned fees in connection with real estate settlement services. Marketing materials must not suggest or imply any improper referral arrangements.
• Equal Credit Opportunity Act (ECOA): Prohibits discrimination in advertising on the basis of race, color, religion, national origin, sex, marital status, age, or receipt of public assistance income. All advertising must be inclusive and non-discriminatory.
• Fair Housing Act: Prohibits discriminatory advertising in housing-related transactions. Advertisements must not indicate any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin.
• State Laws and Regulations: All advertising must comply with the specific advertising requirements of the California Department of Real Estate (DRE) and the Nationwide Multistate Licensing System (NMLS), as well as any other applicable state regulatory bodies.

Specific Guidelines

In addition to the general principles, the following specific guidelines apply to all advertising and marketing materials:

• Trigger Terms: When an advertisement includes specific credit terms (known as "trigger terms") such as the amount or percentage of any down payment, the number of payments or period of repayment, the amount of any payment, or the amount of any finance charge, the advertisement must also include additional disclosures as required by TILA/Regulation Z. These additional disclosures include the amount or percentage of the down payment, the terms of repayment, and the Annual Percentage Rate (APR), using that term or the abbreviation "APR." If the APR may be increased after consummation of the transaction, that fact must also be disclosed.
• Testimonials and Endorsements: Any testimonials or endorsements used in advertising must be genuine, accurately represent the experience of the individual providing the testimonial, and comply with FTC guidelines. If a testimonial does not represent typical results, a clear and conspicuous disclaimer must be included.
• Social Media and Online Advertising: All social media posts, online advertisements, website content, and digital marketing materials are subject to the same advertising standards as traditional media. Due to character or space limitations on certain platforms, required disclosures may be provided via a clearly labeled and easily accessible link. All online advertising must also comply with the CAN-SPAM Act for email marketing and any applicable state laws.
• Third-Party Marketing: Any third-party vendors, affiliates, or partners creating or distributing advertising materials on behalf of Bay Arealty — Genesis Loans must adhere to this policy. Bay Arealty — Genesis Loans retains the right to review and approve all third-party marketing materials prior to publication or distribution.

Review and Approval Process

To ensure compliance, all advertising and marketing materials must undergo a review and approval process before publication or distribution:

• Pre-Approval: All new advertising and marketing materials, including revisions to existing materials, must be submitted to the designated compliance officer or compliance department for review and approval prior to use. This includes, but is not limited to, print advertisements, digital ads, social media content, email campaigns, flyers, brochures, website content, and scripts for radio or television commercials.
• Recordkeeping: Copies of all approved advertising and marketing materials, along with their approval documentation, must be retained for a minimum period as required by applicable laws and regulations (typically a minimum of three years). Records should include the date of approval, the approving party, and the medium and dates of distribution.

Consequences of Non-Compliance

Failure to comply with this Advertising and Marketing Policy may result in:

• Disciplinary Action: Employees or contractors who violate this policy may be subject to disciplinary action, up to and including termination of employment or contract. The severity of the disciplinary action will depend on the nature and extent of the violation.
• Legal and Regulatory Penalties: Non-compliance with advertising laws and regulations can result in significant fines, penalties, cease-and-desist orders, license suspension or revocation, and other legal actions by federal and state regulatory agencies.

Policy Updates

This Advertising and Marketing Policy is subject to periodic review and updates to reflect changes in applicable laws, regulations, and industry best practices. All employees and contractors will be notified of any material changes to this policy. It is the responsibility of all personnel to stay informed of and adhere to the most current version of this policy.

Disclaimer

Bay Arealty — Genesis Loans, NMLS #368880 | DRE #01447306, located at 1313 N Milpitas Blvd, Suite 235, Milpitas, CA 95035. Phone: +1 408-662-5145 | Email: bayarealty.genesisloans@gmail.com. Bay Arealty — Genesis Loans does not provide legal, tax, or financial advice or guidance and is not associated with any government agency. This is not an offer for extension of credit nor a commitment to lend. Programs, rates, terms and conditions subject to change without notice. Certain restrictions may apply. All approvals are subject to underwriting guidelines and minimum credit requirements. Not all loans or products are available in all states. As a result of refinancing, your total finance charges may be higher over the life of the loan. Minimum and maximum loan amounts apply. For current licensure information, please visit: https://www.nmlsconsumeraccess.org.