Steadworth Electronic
Fund Transfers Policy

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to complying with the Electronic Fund Transfer Act ("EFTA") and its implementing regulations (Regulation E) to protect the rights of consumers with regard to electronic fund transfers ("EFTs"). This Policy outlines Steadworth's procedures for authorizing and processing EFTs related to its Home Wealth Share Program ("Program").

II. Policy Statement

Steadworth will comply with all applicable provisions of EFTA and Regulation E, including:

• Obtaining proper authorization for EFTs.

• Providing required disclosures to consumers.

• Protecting consumer information.

• Resolving errors promptly.
  
  

III. Scope

This Policy applies to all EFTs initiated or processed by Steadworth in connection with the Program, including:

• One-time payments initiated using checking information.

• Preauthorized EFTs for recurring payments.

• Collection of fees via ACH.
  
  

IV. 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 EFTA and Regulation E.
  
  

B. Customer Service Team:

• The Customer Service Team is responsible for obtaining proper authorization for EFTs and providing required disclosures to consumers.
  
  

C. All Employees:

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

V. Authorization and Disclosures

A. One-Time Payments:

• Steadworth will obtain consumer authorization for each one-time EFT initiated using checking information.

• Consumers will be provided with a notice informing them that the transaction may be processed as an EFT and outlining their rights.
  
  

B. Preauthorized EFTs:

• Steadworth will obtain a signed or similarly authenticated written authorization from the consumer before initiating any Preauthorized EFTs.

• Consumers will be provided with a copy of the authorization and informed of their right to revoke authorization at any time.

• If the amount of the Preauthorized EFTs will vary, Steadworth will provide consumers with advance notice of the amount and date of each transfer.
  
  

VI. Returned Item Fees

• Steadworth will disclose the amount of any fees and obtain consumer authorization before initiating an EFT to collect the fee.
  
  

VII. Prohibition Against Compulsory Use

Steadworth will not require consumers to enroll in Preauthorized EFTs as a condition for participating in the Program.

VIII. Recordkeeping

Steadworth will maintain records of all EFT authorizations and disclosures for at least two years.

IX. Review and Revision

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

X. Conclusion

Steadworth is committed to protecting the rights of consumers and complying with all applicable laws and regulations regarding EFTs. This Policy is intended to ensure that all EFTs are processed in a safe, secure, and compliant manner.

XI. 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.