Fair Lending Practices

Bay Arealty — Genesis Loans Fair Lending Policy

Bay Arealty — Genesis Loans (NMLS #368880 | DRE #01447306) is firmly committed to fair lending practices and ensuring that all individuals have equal access to mortgage credit regardless of any characteristic protected by law.

Effective Date

This Fair Lending Policy is effective as of January 1, 2026 and applies to all mortgage lending activities conducted by Bay Arealty — Genesis Loans.

Purpose

The purpose of this Fair Lending Policy is to outline Bay Arealty — Genesis Loans' commitment to complying with all applicable fair lending laws and regulations, including but not limited to the Equal Credit Opportunity Act (ECOA), the Fair Housing Act, and all related federal and state statutes. We are dedicated to providing fair, equitable, and nondiscriminatory access to credit for all applicants and borrowers.

Prohibited Bases of Discrimination

Bay Arealty — Genesis Loans strictly prohibits discrimination in any aspect of a credit transaction based on the following protected characteristics:

• Race: No applicant shall be treated differently or unfavorably based on their race or ethnicity.
• Color: Discrimination based on skin color is strictly prohibited in all lending decisions.
• Religion: An applicant's religious beliefs or affiliations shall not influence lending determinations.
• National Origin: No applicant shall be denied credit or offered less favorable terms due to their country of origin or ancestry.
• Sex: Lending decisions shall not be influenced by an applicant's sex, gender identity, or sexual orientation.
• Marital Status: An applicant's marital status shall not be used as a basis for credit decisions, except as permitted by law for the purpose of determining property rights.
• Age: No applicant shall be discriminated against due to age, provided the applicant has the legal capacity to enter into a binding contract.
• Receipt of Income from Public Assistance: An applicant's receipt of income from any public assistance program shall not be used as a basis for denying credit or offering less favorable terms.
• Good Faith Exercise of Rights under the Consumer Credit Protection Act: No applicant shall be penalized or discriminated against for exercising any right under the Consumer Credit Protection Act in good faith.

Fair Lending Practices

Bay Arealty — Genesis Loans implements the following practices to ensure compliance with fair lending requirements:

• Objective Criteria: All loan applications are evaluated based on objective, creditworthiness-related criteria including income, assets, employment history, credit history, and debt obligations. Subjective or discriminatory factors play no role in our lending decisions.
• Consistent Underwriting: We apply consistent underwriting standards to all applicants regardless of any protected characteristic. Our underwriting guidelines are applied uniformly and are reviewed regularly to ensure fairness and compliance.
• Pricing and Terms: Loan pricing, interest rates, fees, and terms are determined based on legitimate business factors such as credit risk, loan-to-value ratio, and market conditions. We do not vary pricing or terms based on any prohibited characteristic.
• Marketing and Outreach: Our marketing and advertising efforts are designed to reach a broad and diverse audience. We do not target or exclude any group based on protected characteristics, and we ensure our materials reflect our commitment to serving all communities.
• Employee Training: All employees involved in the lending process receive regular training on fair lending laws, regulations, and company policies. Training covers the identification and prevention of discriminatory practices, unconscious bias, and the proper handling of loan applications.
• Monitoring and Reporting: Bay Arealty — Genesis Loans conducts regular internal reviews and audits of lending data to identify and address any patterns or practices that may indicate potential fair lending concerns. We maintain compliance with the Home Mortgage Disclosure Act (HMDA) and other reporting requirements.

Complaint Resolution

Bay Arealty — Genesis Loans takes all complaints regarding potential discrimination or unfair lending practices seriously. If you believe you have been discriminated against, you may:

• Contact Us Directly: Bay Arealty — Genesis Loans, 1313 N Milpitas Blvd, Suite 235, Milpitas, CA 95035. We will promptly investigate your complaint and take appropriate corrective action.
• File a Complaint with the CFPB: Consumer Financial Protection Bureau — Online: https://www.consumerfinance.gov/complaint/ | Phone: (855) 411-CFPB (2372) | Mail: Consumer Financial Protection Bureau, P.O. Box 4503, Iowa City, Iowa 52244.
• File a Complaint with HUD: U.S. Department of Housing and Urban Development — Online: https://www.hud.gov/program_offices/fair_housing_equal_opp/online-complaint | Phone: (800) 669-9777.

Consequences of Non-Compliance

Any employee found to be in violation of this Fair Lending Policy or any applicable fair lending law or regulation will be subject to disciplinary action, up to and including termination. Bay Arealty — Genesis Loans may also report violations to the appropriate regulatory authorities. We are committed to maintaining a culture of compliance and accountability at all levels of the organization.

Commitment to Fair Lending

Bay Arealty — Genesis Loans reaffirms its unwavering commitment to fair lending. We believe that equal access to credit is a fundamental right and that our lending practices must reflect the highest standards of fairness, integrity, and compliance. We will continue to review and update our policies and procedures to ensure ongoing adherence to all fair lending requirements and to foster an inclusive lending environment for all.

Disclaimer

Bay Arealty — Genesis Loans, NMLS #368880 | DRE #01447306, located at 1313 N Milpitas Blvd, Suite 235, Milpitas, CA 95035. 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.