I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to providing fair and equal access to its Home Wealth Share Program ("Program") for all applicants, regardless of their race, color, religion, national origin, sex, marital status, age, or any other protected characteristic as defined by the Equal Credit Opportunity Act ("ECOA"). This Equal Opportunity Policy ("Policy") outlines Steadworth's commitment to adhering to the principles of fair lending and non-discrimination.

II. Policy Statement

Steadworth will not discriminate against any applicant on a prohibited basis in any aspect of the Program. This includes, but is not limited to:

• Marketing and soliciting the Program.

• Accepting and processing applications.

• Evaluating eligibility for the Program.

• Setting the terms and conditions of the Program.

• Furnishing information to consumer reporting agencies.

• Managing and administering the Program.
  
  

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents involved in any aspect of the Program.

IV. Prohibited Bases for Discrimination

Steadworth will not discriminate based on the following protected characteristics:

• Race

• Color

• Religion

• National origin

• Sex

• Marital status

• Age (provided the applicant has the capacity to contract)

• Receipt of public assistance income

• Exercise of rights under the Consumer Credit Protection Act
  
  

V. Nondiscriminatory Eligibility Evaluation

Steadworth will evaluate all Program applications based on nondiscriminatory factors, such as:

• Income

• Employment history

• Credit history

• Debt-to-income ratio

• Property valuation

Steadworth will not consider any prohibited basis when evaluating eligibility for the Program.

VI. Prohibited Information Requests

Steadworth will not request or collect any information that is prohibited by ECOA, such as information about an applicant's race, religion, or sex.

VII. Signature Requirements

Steadworth will not require the signature of an applicant's spouse or other person on any Program agreement unless:

• It is necessary to make collateral available to satisfy the obligations under the agreement.

• The additional party's liability is necessary to support the applicant's participation in the Program.

• The applicant is relying on the income of another person and the person's signature is necessary to make the income available to fulfill the obligations under the Program.

• The application is a joint application.
  
  

VIII. Notice of Action Taken

Steadworth will notify all applicants of the action taken on their Program application within 30 days of receiving a completed application. This notification will be provided regardless of whether the application is approved or denied.

IX. Responsibilities

A. Compliance Officer:

• The Compliance Officer is responsible for overseeing and implementing this Policy.

• This includes developing and maintaining procedures, providing training to employees, and monitoring compliance with this Policy.
  
  

B. All Employees:

• All employees are responsible for complying with this Policy and reporting any potential violations to the Compliance Officer.
  
  

X. Training

Steadworth will provide regular training to its employees on fair lending and non-discrimination principles. This training will cover topics such as the prohibited bases for discrimination, nondiscriminatory eligibility evaluation, and prohibited information requests.

XI. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

XII. Conclusion

Steadworth is committed to providing fair and equal access to its Home Wealth Share Program for all applicants. This Policy is intended to ensure that all employees are aware of their obligations to adhere to fair lending and non-discrimination principles and that Steadworth complies with all applicable laws and regulations.

XIII. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at: contact@steadworth.com

Please note: This Policy is intended to supplement, not replace, any other applicable Steadworth policies or procedures.