Steadworth Truth in Lending Act (TILA) Policy for the Home Wealth Share Program

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to complying with the Truth in Lending Act ("TILA") and its implementing regulations (Regulation Z) to ensure that consumers are provided with clear and accurate disclosures about the cost of participating in the Home Wealth Share Program ("Program"). This Policy outlines Steadworth's procedures for providing TILA disclosures to consumers in connection with the Program.

II. Policy Statement

Steadworth will provide consumers with all required TILA disclosures in a timely and accurate manner. These disclosures will be clear, conspicuous, and in a form that the consumer can keep.

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents involved in offering or extending the Program to consumers.

IV. Definitions

• Consumer: An individual who obtains or has obtained the Program from Steadworth for personal, family, or household purposes.

• Annual Percentage Rate (APR): A measure of the cost of credit, expressed as a yearly rate.

• Finance Charge: The cost of credit, including interest and other fees.
  
  

V. Applicability of TILA

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

VI. Disclosure Requirements (If Applicable)

If Steadworth's Program is determined to be covered by TILA, Steadworth will provide consumers with the following disclosures, as applicable:

• Amount Financed: The amount of the down payment investment provided by Steadworth.

• Finance Charge: The total cost of participating in the Program, including any fees and Steadworth's share of the home's appreciation.

• APR: The cost of participating in the Program expressed as a yearly rate.

• Payment Schedule: A description of how and when Steadworth's investment and share of appreciation will be repaid.

• Total of Payments: The total amount the consumer will have paid to Steadworth when the Program agreement ends.
  
  

VII. Timing of Disclosures (If Applicable)

If TILA disclosures are required, Steadworth will provide them to consumers before they become contractually obligated on the Program.

VIII. Marketing and Advertising

All marketing and advertising materials for the Program will comply with TILA's advertising requirements, if applicable. This includes, but is not limited to, accurately stating the APR and other material terms of the Program.

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 TILA, 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.
  
  

X. Training

Steadworth will provide regular training to its employees on TILA compliance, if applicable.

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 consumers with clear and accurate disclosures about the cost of participating in the Program. This Policy is intended to ensure that Steadworth complies with all applicable provisions of TILA and Regulation Z, to the extent applicable.

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.