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[Bank] Corporation and its subsidiaries and affiliates, which includes [Bank], N. A.
(“Bank”), is committed to meeting the credit needs of the entire community in which it
does business. The Bank recognizes its responsibility for ensuring the members of the
communities it serves receive equal access to credit products and services and to respond
to all persons in the credit process without regard to any prohibited bases as listed in the
stated commitment to fair lending. (See Credit Policy §xxx)

In support of the Bank’s commitments, [Risk Management] - Compliance has established
a Fair Lending Program, described below, that is facilitated by a Fair Lending Manager
who monitors fair lending performance and efforts on a company wide basis.

Disparate Treatment

[Bank] will not tolerate illegal discrimination by any of its officers, employees, or agents
against any current or potential credit customer / applicant. Discrimination is not only
overt mistreatment of applicants, but also extends to more subtle forms of unequal
treatment, including giving higher quality of assistance only to applicants who are not
members of a protected class. No one may discriminate against any applicant on any
prohibited bases.

Disparate Impact

The Bank is committed to assuring that policies and practices do not have an adverse
effect on applicants on a prohibited basis. Such a result is not only unfair to the
applicants involved, but deprives the Bank of valuable business it might otherwise obtain.

In order to assure that no standards and / or practices may have an unintentional
discriminatory effect, the Fair Lending Manager reviews proposed new and revised
lending-related policies and procedures. Any standards or practices questioned in such a
review are subject to scrutiny to assure they are needed, are reasonable and that there is
not an alternative with less adverse effect.

Prevention and Detection

The Bank strives to both prevent illegal discrimination from happening and attempts to
detect any possible occurrences. It utilizes a three-pronged strategy: training for all
applicable employees, a self-assessment mechanism and a second review program.

1.     Training

       Annually, all applicable employees will be provided with training appropriate to
       their job responsibilities in fair lending issues. This will include information
       regarding both technical requirements, as well as more substantive and often
       subtle issues relating to unintentional discrimination and quality of assistance.

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2.     Self-Assessment

       The fair lending self-assessment process includes traditional monitoring and audit
       processes. A detailed description of the process is stated below.

3.     Second Review

       For all residential loans, a second review program exists to take a second look at
       all applications that are slated for denial by the underwriter. The second review
       will be conducted by the department’s underwriting manager who has no
       involvement with the original application and underlying transaction. The
       purpose of the second review will not be to conclude if a denial is justified, but to
       determine if there is some way that the credit can be made.

       For all other types of consumer loans as well as for small business credits, the
       origination process is backroom (i.e., there is no face-to-face interaction with the
       applicants), primarily automated and high volume. Thus, it was determined that a
       second review would not add value to the process.


  Board of Directors

       The board of directors formally adopted a commitment to fair lending.
       Additionally, the board remains informed of fair lending performance through
       periodic evaluation of internal and agency examination reports. The board holds
       all appropriate employees accountable for the Bank’s fair lending performance.

  Senior Management

       The Chief Compliance Officer and other senior managers assure that an
       appropriate fair lending program is established to comply with stated
       commitments. Senior management will also assure that a positive fair lending
       culture exists in our organization, as set by their example and behavior. Senior
       management holds all appropriate employees accountable for fair lending

  Fair Lending Manager
       The member of [Risk Management]–Compliance’s Bank Compliance Team
       assigned responsibility for Regulation B, Fair Housing, and back up support for
       HMDA and CRA is designated as the Fair Lending Manager. In addition to
       maintaining expertise for those assigned regulations in accordance with [Risk
       Management]-Compliance policies, the Fair Lending Manager is also responsible
       for monitoring the Bank’s fair lending performance company wide. The Fair
       Lending Manager regularly reports to the Chief Compliance Officer regarding fair

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lending performance, who in turn reports any irregularities in that performance to
the board.

The Fair Lending Manager will assure technical compliance requirements of the
fair lending laws and regulations are met, including:

          Applications / Monitoring Information – Credit applications will
           request only allowable information. In addition, required government
           monitoring information will be collected for applicants seeking to
           finance / refinance the purchase of a dwelling that is, or will be, the
           applicant’s primary residence and is secured by the dwelling.

          Proper Notification – Applicants for credit must be notified of the
           action taken within 30 calendar days from receiving their completed
           applications. Consumer and small business (under $1M in revenues)
           applicants must be notified in writing, as must large businesses if they
           request it.

           Any written notice of adverse action (denial or counteroffer) must
           include the required information as proscribed by Regulation B and the
           FCRA. Any written notice of incompleteness must also include the
           required statements specifying by Regulation B.

          Lobby Notice – The current Equal Housing Lender poster will be
           posted prominently in all offices as required.

The Fair Lending Manager is also responsible for assuring the appropriate level of
compliance management is met by:

          Ensuring fair lending training is made available annually to all
           applicable employees to assure compliance with the Bank’s
           commitment and the underlying laws and regulations. This training
           may be in the form of classroom and / or assigned reading material.

          Analyzing new and modified products, underwriting standards,
           marketing strategies, pricing guidelines, exception policies and other
           credit procedures relating to creditworthiness for potential disparate
           impact on a protected class and overall assurance of compliance with
           fair lending. This may include participation on task forces as
           necessary to provide upfront feedback, responding to employee
           questions and reviewing policies and procedures.

          Ensuring credit advertisements, lobby notices, brochures, signs and
           other promotional material are reviewed by the compliance officer
           assigned responsibility for marketing reviews to assure their
           compliance with fair lending.

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                  Reviewing credit scoring reports to ensure exceptions remain at an
                   acceptable level and are in accordance with the Bank’s exception

                  Scrutinizing HMDA reports to determine whether denial rates for
                   minorities are at an acceptable level. If levels are found to be
                   unacceptable, the Fair Lending Manager will ask Compliance to
                   initiate a self-assessment of questionable areas.

                  Giving consideration to the need for [Risk Management]-Compliance
                   to conduct fair lending self-assessment measures within integrated
                   evaluations and / or initiate self-assessment measures in high risk
                   areas, as well as participate in / oversee the integrated evaluations, as
                   needed. (See Self-Assessment / Comparative File Review, below).

                  Regularly reviewing complaints received for any indication of
                   problems that could lead to examiner criticism of, or civil liability for,
                   the Bank’s fair lending performance. Recommendations are made to
                   management for actions to address any significant complaints.

 Other Staff

       All employees are expected to cooperate with and support fair lending compliance
       efforts. Staff will be held accountable for any lack of cooperation that weakens
       fair lending performance, as reflected in internal evaluations, agency examinations
       and / or consumer complaints.

Self-Assessment Process/Comparative File Review

When the Fair Lending Manager determines the need for conducting comparative file
review analyses, the procedure will follow the OCC guidelines. In summary, the
following steps will be taken:

1. Initial scoping is considered by determining:
     a. Products Offered: By business unit / type of underwriting involved
     b. Decision Making: Centralized or not?

2. Determination of which of the following risk factors are legitimate possibilities to
   assist determination of appropriate focal points. For example, because Corporate
   Compliance reviews all applicable policies and marketing to ensure no overt
   discrimination is present, those factors can be eliminated.

      O1: Including explicit prohibited basis identifiers in underwriting criteria or
       pricing standards.
      O2: Collecting information, conducting inquiries, or imposing conditions
       contrary to express requirements of Regulation B.

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   O3: Including variables in a credit scoring system that constitute a basis or factor
    prohibited by Regulation B or, FHA.
   O4: Statements made by the institution’s officers, employees, or agents which
    constitute an express or implicit indication that one of more such persons have
    engaged or do engage in discrimination on a prohibited basis in any aspect of a
    credit transaction.
   O5: Employee or institutional statements that evidence attitudes based on
    prohibited basis prejudices or stereotypes.

   U1: Substantial disparities among the approval/denial rates for applicants by
    monitored prohibited basis characteristic (especially within income categories).
   U2: Substantial disparities among the application processing times for applicants
    by monitored prohibited basis characteristic (especially within denial reason
   U3: Substantially higher proportion of withdrawn / incomplete applications from
    prohibited basis group applicants than from other applicants.
   U4: Vague or unduly subjective underwriting criteria.
   U5: Lack of clear guidance on making exceptions to underwriting criteria,
    including credit scoring overrides.
   U6: Lack of clear loan file documentation regarding reasons for any exceptions to
    normal underwriting standards, including credit scoring overrides.
   U7: Relatively high percentages of either exceptions to underwriting criteria or
    overrides of credit score cutoffs.
   U8: Loan officer or broker compensation based on loan volume (especially loans
    approved per period of time).
   U9: Consumer complaints alleging discrimination in loan processing or in
    approving / denying residential loans.

   P1: Relationship between loan pricing and compensation of loan officers or
   P2: Presence of broad discretion in pricing or other transaction costs.
   P3: Use of a system of risk-based pricing that is not empirically based and
    statistically sound.
   P4: Substantial disparities among prices being quoted or charged to applicants
    who differ as to their monitored prohibited basis characteristics.
   P5: Consumer complaints alleging discrimination in residential loan pricing.

   R1: Significant differences, as revealed by HMDA data, in the number of loans
    originated in those areas in the lender’s market that have relatively high
    concentrations of minority group residents compared with areas with relatively
    low concentrations of minority residents.
   R2: Significant differences between approval / denial rates for all applicants
    (minority and nonminority) in areas with relatively high concentrations of
    minority group residents compared with areas with relatively low concentrations
    of minority residents.

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      R3: Significant differences between denial rates based on insufficient collateral
       for applicants from areas with relatively high concentrations of minority residents
       and those areas with relatively low concentrations of minority residents.
      R4: Other patterns of lending identified during the most recent CRA examination
       that differ by the concentration of minority residents
      R5: Explicit demarcation of credit product markets that excludes MSAs, political
       subdivisions, census tracts, or other geographic areas within the institution’s
       lending market and having relatively high concentrations of minority residents
      R6: Policies on receipt and processing of applications, pricing, conditions or
       appraisals and valuation, or on any other aspect of providing small business credit
       that vary between areas with relatively high concentrations of minority residents
       and those areas with relatively low concentrations of minority residents
      R7: Employee statements that reflect an aversion to doing business in areas with
       relatively high concentrations of minority residents.
      R8: Complaints or other allegations by consumers or community representatives
       that the lender excludes or restricts access to credit for areas with relatively high
       concentrations of minority residents.

      M1: Advertising patterns or practices that a reasonable person would believe
       indicate prohibited basis customers are less desirable.
      M2: Advertising only in media serving nonminority areas of the market.
      M3: Marketing through brokers or other agents that the lender knows (or has
       reason to know) would serve only one racial or ethnic group in the market.
      M4: Use of marketing programs or procedures for residential loan products that
       exclude one or more regions or geographies within the lender’s assessment or
       marketing area that have significantly higher percentages of minority group
       residents than does the remainder of the assessment or marketing area.
      M5: Using mailing or other distribution lists or other marketing techniques for
       pre-screened or other offerings of residential loan products that exclude groups of
       borrowers or geographies.
      M6: Proportion of monitored prohibited basis applicants is significantly lower
       than that group’s representation in the total population of the market area.
      M7: Consumer complaints alleging discrimination in advertising or marketing

3. Select loan program(s) to be evaluated based on existence of highest discrimination
   possibility as well as the sections within the portfolio containing similar underwriting
   criteria, similarity of collateral, etc.

4. Select sample focal minority group(s). Considerations include size of group (is it
   statistically significant?) and the plausibility of determining ethnicity and / or gender
   of the applicants. Once selected, develop a report that segregates white male
   approvals and denials for the focal minority group(s) selected. This selection may
   need to be honed by eliminating high approvals and low denials to make it more

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5. Create applicant profile spreadsheet. Determine primary credit criteria based on input
   from Credit Exam, the business unit underwriting manager and others familiar with
   the process. Prepare evaluation sheets for each sample applicant to ultimately create a
   database for review.

6. Review spreadsheet to determine potential matches. Once the information has been
   gathered for each selected applicant, establish a Comparative File Review Council to
   review the spreadsheet information for determination of possible comparative
   matches. Past groups have included the Fair Lending Manager, other Corporate
   Compliance employees with knowledge of the business unit’s underwriting standards
   and Credit Exam employees. In preparation for the review, create spreadsheets to sort
   the data through various criteria (e.g., credit score, debt service ratio, LTV,
   bankruptcy, collections, charge offs). Eliminate those applicants with glaring
   problems (e.g., debt service ratios exceeding anything seen in the approvals,
   unverifiable information, counteroffers that were not accepted).        Compare the
   remaining denials against the approvals to determine if any compared equally or more
   favorably to the benchmarks.

   For each potential comparables found, consult the business unit underwriting manager
   to determine if an explanation exists. If no comparables exist or if the underwriting
   manager can sufficiently explain potential issues, then no fair lending issues exist.
   For unexplained comparables, appropriate corrective action must be taken

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Policy Title: Fair Lending Program

Policy Last Revised: (MM/YYYY): December 2002

Institution Asset Size (in Millions): $36 Billion

Primary Federal Regulator: OCC

Geographic Market Scope:
    Majority Non-MSA (Primarily rural business footprint),
    Majority Single MSA,
    Majority Single State,
    Multi-MSA (urban concentration),
    Multi-state,
    Regional,
    National

E-Banking Capability:
    Web Site Used to Advertise Deposit or Loan Products (but cannot conduct banking transactions
    Web Site Used to Conduct Payments or Transactions (but cannot open accounts or make loan
    Web Site Used to Conduct banking transactions and Open Accounts or Make Loan
    None of the above.

Exam Endorsement: (MM/YYYY of Last Compliance Exam: _________)
     Policy not reviewed at last exam,
     Policy reviewed at last exam (and no adverse mention made),
     Policy received favorable oral or written mention at last exam.
Please note year if policy received favorable mention at exam prior to last exam and has not been criticized
by examiners since then (MM/YYYY of favorable mention: _________)

Submitter’s Suggestions: (ID Caveats or Helpful Hints)1
This document is intended as a program outline rather than specific policy, which is imbedded in
business unit policy rather than carved out to stand alone.

1   Please correct or carry forward relevant suggestions when you submit your adapted policy benchmark.
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