VanDyk Mortgage Corporation’s
Fair Lending Policy Statement
It is, and shall be, the policy of VanDyk Mortgage Corporation ("VanDyk") to make its credit products available to all qualified applicants without discrimination on the basis of race, color, sex, religion, age,national origin, handicap, marital or familial status, receipt of public assistance, or good faith exercise of rights under the Federal Consumer Protection Act. It is, and will continue to be, VanDyk's policy not to discourage the submission of an application for credit by any applicant on any of the prohibited areas listed above. All consumers are to be treated fairly, consistently, and in compliance with fair lending laws, according to VanDyk’s policy.
Our employees will consistently offer fair service, any needed assistance, and continued encouragement. VanDyk will also clearly communicate our fair lending policy to all of our brokers and correspondents. The credit needs of low and moderate income neighborhoods within our community shall have special attention dedicated to them by VanDyk. VanDyk shall provide financial services to all income segments of our market that are consistent with safe and sound lending practices. The advertising of VanDyk, as well as all of its communications to the public shall be portrayed in way making it clear that VanDyk does not discriminate on a prohibited basis. VanDyk will commence specific activities to encourage a wide range of clients to approach its offices and to consider us as a financial service resource. The success of VanDyk's Fair Lending Program is the responsibility of the entire organization. VanDyk's fair lending practices apply across all aspects of our operations, including marketing, loan origination, processing, underwriting, servicing, and collection activities.
Our company’s structure and organization, training, technology, employee accountability, and continued monitoring and auditing of programs demonstrate VanDyk's commitment to fair lending. Our Chief Executive Officer and the Executive Management team is responsible for establishing practices designed to ensure that our operations reflect our strong commitment to fair lending and that all employees are aware of, as well as following that commitment. At VanDyk we are dedicated to providing superior service to our clients through teamwork, admirable professionalism, and promise to action. Fair treatment of all clients is, and shall be, our primary focus as we identify ways to continue to meet our commitment to fair lending.
VanDyk ensures that its employees are educated on the rules of fair lending using the following tactics:
Training new and existing employees on an annual basis with regards to the fair lending laws and regulations
The training includes a detailed, informative PowerPoint and follow up quiz
Distributing a fair lending brochure that contains extensive background on fair lending rules and government regulatory agencies to every employee in VanDyk bi-annually
Monitoring the Loan Approval Process
To make sure our applicants are treated fairly in the loan approval process, VanDyk follows the steps listed below: 2Rev. 11.8.13
Annually conduct a fair lending examination of all credit policies
An independent team of fair lending underwriters reviews the targeted files of approved and declined applications to confirm consistency in the credit decision. If one of these underwriters find an application that was inappropriately declined, then an offer of credit is made
Re-evaluate all declined first mortgage applications a second time by a more experienced underwriter
Fair Pricing Initiatives
In order to ensure that loans are priced fairly, VanDyk follows the following procedures:
Monitor loan pricing for compliance with fair lending laws
Test loans to confirm that the pricing and fees do NOT exceed HOEPA thresholds
Company Oversight of Fair Lending within VanDyk, each production channel has regular fair lending meetings with senior executives with oversight responsibilities, including VanDyk's Corporate Fair Lending Officer.
VanDyk has its own weekly fair lending team meeting to discuss the status and cause of any fair lending complaints, fair lending training efforts, progress against the fair lending plan, and data trends and analysis.