Steadworth Fair Collections Practices Policy

Effective Date: Not Effective Currently

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to collecting payments under its shared appreciation agreements in a fair, transparent, and compliant manner. This Fair Collections Practices Policy ("Policy") outlines Steadworth's procedures for collecting payments from consumers in accordance with applicable laws and regulations, including the principles of the Fair Debt Collection Practices Act (FDCPA).

II. Policy Statement

Steadworth will comply with all applicable laws and regulations governing the collection of payments under its shared appreciation agreements, including the principles of the FDCPA. This includes:

Prohibiting harassment and abuse.
Prohibiting false and misleading representations.
Prohibiting unfair practices.
Providing required disclosures to consumers.

III. Scope

This Policy applies to all Steadworth employees and agents involved in the collection of payments from consumers under Steadworth's Home Wealth Share Program ("Program").

IV. Prohibited Practices

Steadworth employees and agents are prohibited from engaging in the following practices:

A. Harassment and Abuse:

Using or threatening violence or other criminal means.
Using obscene or profane language.
Publishing lists of consumers who allegedly refuse to pay.
Causing a telephone to ring repeatedly or continuously.
Contacting consumers at their place of employment if the employer prohibits such contact.

B. False and Misleading Representations:

Falsely representing or implying affiliation with the government.
Falsely stating the nature, amount, or status of a payment obligation.
Falsely representing or implying that the collector is an attorney.
Threatening to take action that is not permitted by law.
Failing to disclose that the communication is from a debt collector.

C. Unfair Practices:

Collecting any amount not expressly authorized by the agreement or by law.
Depositing or threatening to deposit post-dated checks.
Causing consumers to incur charges for communications.
Taking or threatening to take non-judicial action to obtain possession of property without legal authority.
Communicating with consumers by postcard.
Using language or symbols on envelopes that indicate the communication is from a debt collector.
Making in-person collection visits to places that may embarrass the consumer.

V. Required Disclosures

Steadworth will provide consumers with the following disclosures as required by applicable laws and regulations:

Initial Communication: The initial communication with the consumer will include the amount of the payment obligation, the name of Steadworth, and a statement that the consumer has the right to dispute the obligation.
Validation Notice: Within five days of the initial communication, Steadworth will send the consumer a written validation notice that includes the amount of the payment obligation, the name of Steadworth, and a statement of the consumer's rights under applicable laws and regulations.

VI. 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.

VII. Training

Steadworth will provide regular training to its employees on fair collection practices and applicable laws and regulations. This training will cover topics such as the prohibited practices, required disclosures, and consumer rights.

VIII. Review and Revision

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

IX. Conclusion

Steadworth is committed to collecting payments under its shared appreciation agreements in a fair, transparent, and compliant manner. This Policy is intended to ensure that all employees are aware of their obligations and that Steadworth conducts its collection activities in accordance with the law.

X. 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.