Financial Predator Avoidance - Non-Predation Lending Standards

1. Market Private Equity Mortgage (PEM) products through government licensed or PEMI®-Certified Professionals.

PEMI®-How? Borrower Be Aware Program.

2. A PEMI®-Certified Professional (Broker, Lender, Banker) does not provide advice to consumer mortgage applicants. Providing retail consumer mortgage advice is the duty of the agent who has been retained by the consumer. If the Consumer interacts with a PEMI®-Certified Professional without the use of an intervening agent, the PEMI®-Certified Professional must provide Customer Disclosure Documents which explicitly states the following:

As PEMI®-Certified Professionals our firm and its representatives WILL ONLY represent the lender(s) and will treat you, the borrower, as a customer of the lender. In this service relationship, we have an obligation to represent the lender’s best interests. You will be treated honestly; and we will exercise reasonable care and skill in providing information with respect to lender(s) mortgage options, progress of the transaction, complete documentation for submission to the lender and communicate information from lender.

As PEMI®-Certified Professionals our firm and its representatives WILL NOT act as an INTERMEDIARY between you and the lender(s) NOR will we represent you. We are not duty­bound to gather your intended property and financial information to determine the lending options available to you; nor are we duty­bound to represent your best interests at any time. Additionally, we will NOT recommend a particular option(s), NOT advocate on your behalf NOR provide confidential advice. If you seek a mortgage brokerage, bank, lender or other credit professional to represent you, or to act as an intermediary, please notify your PEMI®-Certified Professional immediately -­ DO NOT agree to this form or sign it.

PEMI®-How? Borrower Be Aware Program.

2. Operate in a manner that mitigates the Joint HUD-Treasury Report on Recommendations to Curb Predatory Home Mortgage Lending

i) Provide Full Disclosure

ii) Do NOT use aggressive marketing

iii) If borrower is unable to declare that they have an ability to pay, yet still seeks the loan, ensure the borrower secures independent legal advice and/or provides an acknowledgement of situational understanding disclosure document (ASU Doc).

iv) "Price to Risk" using the Accredited Class® Private Lending Underwriting Standard (APLUS).

v) Ensure the agent of the borrower explains a PEMI®-Certified PEM product is made available as a "last resort" for the applicant. A Qualified Prospect for a PEMI®-Certified Professional is one who has shopped around prior to considering a PEM product. This way the consumer may make the sincere decision of whether or not a PEM approach is best for them, knowing that there are no other apparent options. There is no harm in not borrowing money, or simply selling a property; rather than taking on a loan that is not acceptable to them.

vi) Ensure the agent of the borrower explains to the Borrower that PEM products are designed as short-term, near-term or mid-term financing solutions as a way to sustain a current status quo pending a future event (ie: sale of the asset, or refinance, or obtaining partner equity, or related solution).

PEMI®-How? PEMI® BorrrowSafe Program.

3. Educate the Consumer

PEMI®-How? PEMI® Consumer education courses. Namely: The World of Financial Predation - A Primer for Consumers

4. Offer NonMortgage® solutions if deemed applicable; or convert existing debt to a NonMortgage® equity solution.