Steadworth Military Lending Act (MLA) Policy

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to providing fair and affordable financial products and services to members of the military and their dependents. This Military Lending Act (MLA) Policy ("Policy") outlines Steadworth's procedures for complying with the MLA and its implementing regulations, to the extent applicable.

II. Policy Statement

Steadworth will comply with all applicable provisions of the MLA, including:

• Limiting the Military Annual Percentage Rate (MAPR) to 36% or less, if applicable.

• Providing required disclosures to covered borrowers, if applicable.

• Prohibiting certain practices, such as requiring allotments or prepayment penalties, if applicable.
  
  

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents involved in offering or extending the Home Wealth Share Program ("Program") to covered borrowers.

IV. Definitions

• Covered Borrower: An active duty service member, their spouse, or dependents.

• Consumer Credit: Credit offered or extended to a covered borrower primarily for personal, family, or household purposes.

• Military Annual Percentage Rate (MAPR): The cost of consumer credit expressed as an annual rate, including all applicable fees and charges.
  
  

V. Applicability of the MLA

Steadworth's Program is not a traditional loan and may not be considered consumer credit under the MLA. However, Steadworth will consult with legal counsel to determine the applicability of the MLA to the Program and ensure compliance with all applicable provisions of the law.

VI. Compliance with MAPR Limit (If Applicable)

If Steadworth's Program is determined to be covered by the MLA, Steadworth will ensure that the MAPR for the Program does not exceed 36%.

VII. Covered Borrower Identification

Steadworth will use the Department of Defense's (DoD) MLA database to verify the status of consumers as covered borrowers, if applicable.

VIII. Mandatory Disclosure Obligations (If Applicable)

If Steadworth's Program is determined to be covered by the MLA, Steadworth will provide covered borrowers with the following disclosures before or at the time they become obligated on a transaction:

• A statement of the MAPR applicable to the Program.

• All disclosures required by Regulation Z (Truth in Lending Act).

• A clear description of the payment obligation.
  
  

IX. Limitations (If Applicable)

If Steadworth's Program is determined to be covered by the MLA, Steadworth will not:

• Require a covered borrower to waive their legal rights.

• Submit covered borrowers to arbitration or other onerous legal notice provisions.

• Require unreasonable notice as a condition for legal action.

• Require a covered borrower to establish an allotment to repay the obligation.

• Prohibit a covered borrower from prepaying the obligation.

• Charge a penalty fee for prepaying the obligation.

• Use a check or other method of access to a covered borrower's deposit or savings account.
  
  

X. 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 the MLA, to the extent applicable.
  
  

B. All Employees:

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

XI. Training

Steadworth will provide regular training to its employees on MLA compliance, if applicable. This training will cover topics such as how to identify covered borrowers, MAPR calculation, disclosure requirements, and prohibited practices.

XII. Review and Revision

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

XIII. Conclusion

Steadworth is committed to providing fair and affordable financial products and services to members of the military and their dependents. This Policy is intended to ensure that all employees are aware of their obligations under the MLA, to the extent applicable, and that Steadworth conducts its business in a compliant manner.

XIV. 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.