Northern Lakes Mortgage LLC is a privately licensed non-bank lender authorized to conduct business in the followings states:
Northern Lakes Mortgage LLC is a registered licensed entity in the state of Illinois and registered through the Nationwide Mortgage Licensing System (NMLS) operating with the NMLS #1986026
Interpretation and Definitions:
We do not sell or share data.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Northern Lakes Mortgage LLC, 1010 Market Street Ste 650, St. Louis, MO 63101.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Account means a unique account created for You to access our Service or parts of our Service.
Website refers to Northern Lakes Mortgage LLC, accessible from www.northernlakesmortgage.com
Service refers to the Website.
Country refers to: Illinois, United States
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Personal Data is any information that relates to an identified or identifiable individual.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Collecting and Using Your Personal Data Types of Data Collected Personal Data While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address, First name and last name, Phone number, Usage Data,
Usage Data Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.
We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Use of Your Personal Data The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service. To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. To manage Your requests: To attend and manage Your requests to Us. We may share your personal information in the following situations:
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Disclosure of Your Personal Data
Law enforcement Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation Protect and defend the rights or property of the Company Prevent or investigate possible wrongdoing in connection with the Service Protect the personal safety of Users of the Service or the public Protect against legal liability Security of Your Personal Data The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Your California Privacy Rights (California’s Shine the Light law) Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
By email: [email protected]
Terms of Service
This application is owned and operated by Northern Lakes Mortgage LLC, 1010 Market Street Ste 650, St. Louis, MO 63101, which is referred to below as “Northern Lakes” or “we” or “us” or “Company” or “our.”
You agree that:
You agree that you will not use or attempt to use this application for any purpose other than conducting mortgage banking related business with Northern Lakes Mortgage as a bona fide client of Northern Lakes Mortgage; you may not use or attempt to use this application or any part of this application for any purpose:
- that interferes with or induces a breach of the contractual relationships between Northern Lakes Mortgage and its employees,
- that is any way unlawful or prohibited, or that is harmful or destructive to anyone or their property,
- that transmits any advertisements, solicitations, schemes, spam, flooding, or other unsolicited Email, unsolicited commercial communications,
- that transmits any harmful or disabling computer codes or viruses,
- that harvests Email addresses from this application,
- that transmits unsolicited Email to this application,
- that interferes with our network services;
- that attempts to gain unauthorized access to our network services,
- that suggests an express or implied affiliation with Northern Lakes Mortgage or broker relationship with Northern Lakes Mortgage (without the express written permission of Northern Lakes Mortgage),
- that impairs or limits our ability to operate this application or any other person’s ability to access and use this application, and/or
- that unlawfully impersonates or otherwise misrepresents your affiliation with any person or entity;
- that harms minors in any way, including, but not limited to, transmitting or uploading content that violates child pornography laws, child sexual exploitation laws and laws prohibiting the depiction of minors engaged in sexual conduct;
- that transmits or uploads pornographic, violent, obscene, sexually explicit, discriminatory, hateful, threatening, abusive, defamatory, offensive, harassing, or otherwise objectionable content or images;
- that harms, threatens, harasses, abuses or intimidates another person in any way or involves images or content that depicts, promotes, encourages, indicates, advocates or tends to incite the commission of a crime or other unlawful activities;
- that dilutes or depreciates the name and reputation of Northern Lakes Mortgage or any of its affiliates;
- that transmits or uploads any content or images that infringes any third party’s intellectual property rights or infringes any third party’s right of privacy; or
- that unlawfully transmits or uploads any confidential, proprietary or trade secret information.
- Access To This Application
- Northern Lakes Mortgage reserves the right at all times, in its sole discretion and without notice to you, to deny your access to and use of this application.
Use Of This Application
You agree and acknowledge that you have the sole responsibility and liability for your use of this application and for providing or obtaining, and for maintaining, all of the hardware, software, electrical power, telecommunications, Internet services, and other products or services necessary or desirable for you to access and use this application.
Northern Lakes operates a campaign that sends opted in subscribers texts and messages about financial programs and market updates. Northern Lakes operates a campaign that sends opted in subscribers information about open market conditions, home values and the financial implications of market trends. Northern Lakes also operates campaigns dealing with financial analysis of home instruments at subscriber request.
Message frequency will vary.
Reply Help for more information.
Reply STOP to unsubscribe.
Message and Data rates May apply.
Carriers are not liable for delayed or undelivered messages.
We do not sell or share data
Intellectual Property Rights
The following marks appearing on this application, including, but not limited to: “Ask Northern”, “Northern Lakes Mortgage”, “Northern Lakes” and the respective logos, emblems, slogans and designs are trademarks and/or service marks of Northern Lakes Mortgage, LLC.
“Northern Lakes” is a registered service mark of Intuit Inc., used under license.
All other marks used on this application are the property of their respective owners.
Application Content: You acknowledge and agree that:
- all content, pages, source code, calculations, products, materials, data, information, text, screens, functionality, services, design, layout, screen interfaces, “look and feel”, and the operation of this application (collectively “Application Content”) are protected by various intellectual property laws, including, but not limited to, copyrights, patents, trade secrets, trademarks, and service marks; and
- all rights associated with the Application Content are owned by Northern Lakes Mortgage, its licensors, or content providers.
- Furthermore, you acknowledge and agree that you do not acquire any ownership rights by downloading or viewing any Application Content. You further acknowledge and agree that you will not in any way copy, reproduce, publish, create derivative works from, perform, upload, post, distribute, transfer, transmit, modify, adapt, reverse engineer, frame in any page, or alter the appearance of any Application Content.
You may not use Application Content, domain names (in whole or in part), or Email addresses related to or derived from this application, nor any data, trademarks, functionality, service marks, trade names, brand names and/or logos contained within or derived from this application, for any purpose; meaning that you may not, among other prohibited uses, use any Application Content, domain names, Email addresses, data, trademarks, service marks, trade names, brand names and/or logos on or derived from this website:
- in or as any meta-tag or hidden text;
- in or as part of any contextual marketing directory, index, or triggering term;
- as content or advertising related to any other application including, but not limited to, comparative/informational applications; and/or
as a variable or data element in any algorithm that causes another Internet browser to appear on, over, or at the same time as the Company’s application or controls the content of any other application.
Not Responsible For Links to Other websites: For your convenience, this website may provide links to other websites on the World Wide Web. Unless expressly stated otherwise on this website, Northern Lakes Mortgage does not endorse, approve, sponsor or control, and we are not in any way responsible for, any of the content, services, calculations, information, products or materials available at or through any websites to which this website may provide a link. By using this website you acknowledge and agree that Northern Lakes Mortgage will not be responsible or liable to you or any other person for any damages or claims that might result from your use of such content, services, calculation, information, products or materials.
No Advertising / No Links. Northern Lakes Mortgage does not permit third-party advertising on this website. Except with the written permission of Northern Lakes Mortgage, you agree that you will not create links from any website or Web page to this website or any Web page within this website.
Revisions And Modifications
You understand and acknowledge that Northern Lakes Mortgage controls and operates this application from within the United States of America. This application provides information regarding services and products that are made available in the United States only. We make no representation that the services or products about which information may be provided on this application will be available (a) anywhere outside of the United States or (b) in every state within the United States. You acknowledge and agree that you are responsible for compliance with all federal, state and local laws applicable to your access to and use of this application.
Privacy and Security
For information on how Northern Lakes Mortgage uses and protects the personal information that you may provide through this application, please visit: https://northernlakesmortgage.com/legal.
THE APPLICATION CONTENT ON OR AVAILABLE THROUGH THIS WEBSITE ARE PROVIDED “AS IS” AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW, NORTHERN LAKES MORTGAGE DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. NORTHERN LAKES MORTGAGE MAKES NO REPRESENTATION OR WARRANTY REGARDING THE APPLICATION CONTENT OR ITS USE THEREOF. THE APPLICATION CONTENT ON OR AVAILABLE THROUGH THIS APPLICATION COULD INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS AND COULD BECOME INACCURATE BECAUSE OF DEVELOPMENTS OCCURRING AFTER THEIR RESPECTIVE DATES OF PREPARATION OR PUBLICATION. NORTHERN LAKES MORTGAGE HAS NO OBLIGATION TO MAINTAIN THE CURRENCY OR ACCURACY OF ANY APPLICATION CONTENT ON OR AVAILABLE THROUGH THIS APPLICATION.
YOU ACKNOWLEDGE AND AGREE THAT NORTHERN LAKES MORTGAGE IS NOT, AND SHALL NOT BE, RESPONSIBLE FOR THE RESULTS OF ANY DEFECTS THAT MAY EXIST IN THIS APPLICATION OR ITS OPERATION. AS TO THE OPERATION OF THIS APPLICATION, NORTHERN LAKES MORTGAGE EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. NORTHERN LAKES MORTGAGE MAKES NO REPRESENTATION OR WARRANTY THAT (A) THE OPERATION OF THIS APPLICATION WILL MEET YOUR OR ANY OTHER USER’S REQUIREMENTS; (B) ACCESS TO THE APPLICATION WILL BE UNINTERRUPTED, TIMELY, SECURE, OR FREE OF ERRORS, VIRUSES OR OTHER HARMFUL COMPONENTS; OR (C) ANY DEFECTS IN THIS APPLICATION WILL BE CORRECTED. YOU AGREE THAT YOU, AND NOT NORTHERN LAKES MORTGAGE, WILL BEAR THE ENTIRE COST OF ALL SERVICING, REPAIR, CORRECTION OR RESTORATION THAT MAY BE NECESSARY FOR YOUR DATA, SOFTWARE PROGRAMS OR COMPUTER EQUIPMENT BECAUSE OF ANY VIRUSES, ERRORS OR OTHER PROBLEMS YOU MAY HAVE AS A RESULT OF USING OR VISITING THIS APPLICATION.
My Property Module
The “My Estimated Home Values” are provided “as is” and all uses are at the user’s sole risk. All warranties concerning the values and all underlying data are expressly excluded. The My Estimated Home Values provide an estimated market value generated by proprietary models. The My Estimated Home Values is not an appraisal and is not prepared by a certified or licensed appraiser. THESE VALUES SHOULD NOT BE RELIED UPON AS A VALUE FOR MORTGAGE LOAN ORIGINATION, HOME SALE OR ANY OTHER FINANCIAL PURPOSES.
Limitation Of Liability
YOU AGREE THAT UNDER NO CIRCUMSTANCES WILL NORTHERN LAKES MORTGAGE BE LIABLE TO YOU OR ANY OTHER PERSON OR ENTITY FOR ANY DAMAGES OR INJURY, INCLUDING ANY DIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES OR ANY DAMAGES OR INJURY CAUSED BY ERROR, INACCURACY, OMISSION, INTERRUPTION, DEFECT, FAILURE OF PERFORMANCE, DELAY IN OPERATION OR TRANSMISSION, TELECOMMUNICATIONS FAILURE OR COMPUTER VIRUS OR OTHER PROBLEM, THAT MAY RESULT FROM THE USE OF, OR THE INABILITY TO USE, THIS APPLICATION OR THE APPLICATION CONTENT ON OR AVAILABLE THROUGH THIS APPLICATION, WHETHER IN AN ACTION ALLEGING BREACH OF CONTRACT, NEGLIGENCE OR ANY OTHER CAUSE OF ACTION, OR ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF ANY APPLICATION CONTENT ON OR AVAILABLE THROUGH THIS APPLICATION. YOU AGREE THAT NORTHERN LAKES MORTGAGE SHALL NOT BE LIABLE EVEN IF WE OR OUR AUTHORIZED REPRESENTATIVES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
APPLICABLE LAW MAY NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY TO YOU. HOWEVER, IN NO EVENT SHALL NORTHERN LAKES MORTGAGE’S TOTAL LIABILITY TO YOU FOR DAMAGES, LOSSES, AND CAUSES OF ACTION (WHETHER IN CONTRACT, TORT OR OTHERWISE) EXCEED THE AMOUNT PAID BY YOU, IF ANY, IN ACCESSING OR USING THIS APPLICATION OF APPLICATION CONTENT THEREON.
Communications With Company
Email: For information regarding our Email policy, please visit: https://northernlakesmortgage.com/legal
Time Sensitive Instructions: When communicating with us through this website, PC-talk, chat or via Email, do not use the application, PC-talk, chat or Email to communicate any time-sensitive instructions that are in any way related to or affect your loan, loan application or closing (such as interest rates locks, cancellation of a closing, rescissions, or the like). Such instructions may not be honored. All transactions conducted on this application, PC-talk, chat or via Email, must be confirmed in writing by us to be accepted by and binding upon us.
Loan Approvals: All loan approvals, qualifications, rate locks, deposit and refund agreements, and the like, are only made by Northern Lakes Mortgage in writing. Approvals and qualifications are conditional in accordance with there terms except as be specifically provided for in writing signed by Northern Lakes Mortgage.
Credit Reports: By applying for credit, you are authorizing Northern Lakes Mortgage to obtain a copy of your credit report. As a result, a “hard” inquiry may appear on your credit report. A hard inquiry may negatively affect your credit score.
E-Signature: General communications through this application, PC-talk, chat or via Email are not intended by us to constitute either an electronic record or an electronic signature, or to constitute any agreement by the sender to conduct a transaction by electronic means, unless a specific statement to the contrary is included in the message and specific e-signature procedures are employed. However, your assent to a “click to accept” button or box is binding upon you.
Recording & Monitoring of Communications: Your communications with us via the application, PC-talk, chat Email, and telephone may be recorded or monitored and by using such communications methods you are consenting to the recording or monitoring of the same.
Contact Methods And Opt-Out
By submitting your contact request for a loan product, you are consenting to be contacted by one or more Affiliates, including One Reverse Mortgage and Rocket Homes, and by our mortgage partners by telephone (on a recorded line), automated calling, pre-recorded calling, text message, email, fax, telephone or any means, even if you have opted in to the National Do Not Call List, any state equivalent Do Not Call List or the internal Do Not Call List of any company. You understand that the Affiliates and Partners may maintain the information you submitted to us even if you decide not to use their services. In the event you no longer want to receive communications from an Affiliate or Partner, you agree to notify the Affiliate or Partner directly. You can opt-out of various contact methods by emailing [email protected].
Application Of Additional Terms
Agreement To Provide Accurate Information
In making a loan inquiry, application or in entering into any other transaction or request for information on this website, you agree to provide accurate, true, current, and complete information upon which Northern Lakes Mortgage may rely.
Your Cooperation Needed
Northern Lakes Mortgage generally begins processing your application (which may include ordering an appraisal, credit report, title commitment and other necessary items) upon the submission of a full and complete application. If you submit an application, you agree to cooperate in the application process (including submitting all required documentation in a timely manner) and if needed, to obtain information Northern Lakes Mortgage may need from third parties such as your bank, employer, current mortgage company, etc. In addition, you agree to notify Northern Lakes Mortgage of any changes in any information submitted in connection with your application.
While Northern Lakes Mortgage will use all of its reasonable efforts to have your application fully processed and closed on or before any applicable rate lock expiration date (if any) and/or anticipated closing date, some process are not under our control. For instance, Northern Lakes Mortgage cannot be responsible for delays in loan approval or closing due to: the untimely receipt of an acceptable appraisal; the untimely receipt of required documentation; your existing home not selling; matters disclosed by a title commitment or survey; any other matters beyond Northern Lakes Mortgage’s reasonable control.
When you submit a loan application, Northern Lakes Mortgage will begin to process your application and, as a result, will advance on your behalf costs for certain third party expenses. If you do not fully cooperate in or complete the application process (including submitting all required documentation in a timely manner), choose to withdraw your application, or choose not to close the transaction for any reason, you may be required to pay for some or all of Northern Lakes Mortgage third party costs. Please review your deposit agreement for details specific to your loan application.
Disclosures And Licenses
For disclosures and licensing information please visit: https://northernlakesmortgage.com/legal
Northern Lakes Mortgage is committed to protecting copyrights and expects you to do the same. The Digital Millennium Copyright Act of 1998 (the “DMCA”) provides recourse for copyright owners who believe that material appearing on the Internet infringes their rights under U.S. copyright law. If you believe in good faith that any material used or displayed on the Northern Lakes Mortgage infringes your copyright, you (or your agent) may send us a notice requesting that the material be removed, or access to it blocked. If you believe that any material on this application infringes a copyright, or any valid intellectual property right, please provide the following information to Northern Lakes Mortgage’s DMCA Agent.
A physical or electronic signature that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on this application are intended to be covered by a single notification, a complete list of such works and details or descriptions as to their locations within the application;
Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material;
Information reasonably sufficient to permit us to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted;
A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Please provide this information to Northern Lakes Mortgage’s DMCA Agent, who can be reached as follows:
Northern Lakes Mortgage, LLC
Attn: Legal Team
1010 Market Street Ste 650, St. Louis, MO 63101
Your California Privacy Rights
California Civil Code § 1798.83 permits our visitors who are California residents to request certain information regarding their disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:
Northern Lakes Mortgage, LLC
Attn: Legal Team
1010 Market Street Ste 650, St. Louis, MO 63101
Equal Opportunity Employer
The Company is an equal opportunity employer. Any complaints or concerns about the Company’s employment practices may be directed to the Director of Human Resources at (800) 863-4332.
Fair Lending Policy
This policy outlines Northern Lakes Mortgage LLC’s approach to complying with applicable fair lending laws and regulations. This policy provides guidelines followed by Northern Lakes Mortgage team members to ensure residential home lending activities – during the stages of the lending process, including collection and foreclosure, as applicable – are conducted without regard to the applicant’s/borrower’s race, color, religion, national origin, sexual orientation, military status, sex, marital status, disability, familial status, age (provided the applicant has legal capacity to enter into a binding contract), receipt of public assistance, gender identity or expression in accordance with [GENDA NY Act 747], or the exercise of legal rights under the federal Consumer Credit Protection Act.
Northern Lakes Mortgage LLC (“NLM” or the “Company”) is committed to providing the highest quality loan finance services to applicants and borrowers on an equal, non-discriminatory basis. It is Northern Lakes Mortgage’s policy to treat its applicants and borrowers consistently and in compliance with fair lending laws throughout the loan process, including collection and foreclosure, as applicable. Northern Lakes Mortgage team members are required to offer assistance and services in a fair and consistent manner during the performance of their duties and responsibilities to potential applicants and borrowers without regard to race, color, religion, national origin, sexual orientation, military status, sex, marital status, disability, familial status, age (provided the applicant has legal capacity to enter into a binding contract), gender identity or expression, receipt of public assistance, or the exercise of legal rights under the federal Consumer Credit Protection Act1. Additionally, Northern Lakes Mortgage informs its team members regarding the implementation of policies created to ensure compliance with state and federal fair lending laws, including but not limited to New York Executive Law § 296-a and New York Gender Expression NonDiscrimination Act (“GENDA”)2.
II. FAIR LENDING OVERVIEW
The legal aspects of fair lending are contained in several federal and state laws. The purpose of these laws is to ensure that fair and equal treatment is provided to individuals seeking sales financing.
The federal Equal Credit Opportunity Act (“ECOA”) 3 and its implementing regulation, Regulation B4, prohibit discrimination in a credit transaction. The prohibited bases of discrimination under the ECOA are the following: race; color; religion; national origin; sex; marital status; age (provided that the applicant has the capacity to enter a binding contract); the applicant’s receipt of income through a public assistance program; gender identity or expression; and the good faith exercise of the applicant of a right under the federal Consumer Credit Protection Act5.
- 1115 U.S.C. §§ 1601 et seq.
- 215 U.S.C. §§ 1691 et seq.
- 312 C.F.R. Part 202.
- 4See Supra Note 1.
Various state laws also govern fair lending, including but not limited to New York Executive Law § 296-a and GENDA, which makes it an unlawful discriminatory practice for any creditor to discriminate against any such applicant because of the race, creed, color, national origin, sexual orientation, military status, age, sex, marital status, disability, gender identity or expression, or familial status of such applicant in the granting, withholding, extending or renewing, or in the fixing of the rates, terms or conditions of, any such credit; to use any form of application for credit or use or make any record or inquiry which expresses, directly or indirectly, any limitation, specification, or discrimination as to race, creed, color, national origin, sexual orientation, military status, age, sex, marital status, disability, gender identity or expression, or familial status; to make any inquiry of an applicant concerning his or her capacity to reproduce, or his or her use or advocacy of any form of birth control or family planning; to refuse to consider sources of an applicant’s income or to subject an applicant’s income to discounting, in whole or in part, because of an applicant’s race, creed, color, national origin, sexual orientation, military status, age, sex, marital status, childbearing potential, disability, gender identity or expression, or familial status; or to discriminate against a married person because such person neither uses nor is known by the surname of his or her spouse.
This Policy applies throughout the loan process, including but not limited to, origination, loan servicing, refinancing, collection and foreclosure activity, if applicable. Northern Lakes Mortgage LLC is committed to implementing policies, procedures, team member training, and management oversight to ensure equitable treatment of borrowers. Northern Lakes Mortgage LLC policies and procedures include responding to consumer inquiries, concerns, and complaints in a timely, fair, and consistent manner.
Northern Lakes Mortgage LLC commitment to complying with fair lending laws extends to its relationships with third parties.
Northern Lakes Mortgage LLC commitment to fair lending is reflected in its belief in the shared responsibility for compliance with fair lending laws at every level of the organization.
Northern Lakes Mortgage LLC Senior Management is responsible for approving, adopting, implementing and ensuring that Northern Lakes Mortgage LLC business practices comply with its Fair Lending Policy in the following ways: (i) communicating Northern Lakes Mortgage LLC fair lending policies to the applicable business unit management; (ii) allocating, on an ongoing basis, sufficient resources to ensure the successful implementation of this Policy; (iii) obtaining input and guidance from the Compliance Team and Consumer Advocate on significant business decisions that have potential fair lending impact; and (iv) monitoring results and recommending corrective action where necessary.
The Compliance Team, led by the Chief Compliance Officer (“CCO”), or his/her designee, implements the policies outlined in this Policy in the following ways: (i) monitoring implementation of and adherence to the fair lending policies and procedures; (ii) reviewing and addressing fair lending complaints; (iii) monitoring, as appropriate, Northern Lakes Mortgage LLC’s loan application and underwriting process as well as its pricing policies; (iv) reviewing, on a regular basis, the Fair Lending Policy to determine that it still accurately reflects the policies followed by Northern Lakes Mortgage LLC and conforms to federal and state law; (v) maintaining training materials to keep current with changes in the law, regulation, and judicial interpretation: and (vi) providing, periodically, updates on fair lending issues to Northern Lakes Mortgage LLC team members involved in the loan origination or servicing process.
Fair lending policies are applied in a manner that achieves the Company’s fair lending objectives while at the same time are applied in a manner which is consistent with making safe and sound investment quality loans.
Fair Lending Policy and Loan Process
Northern Lakes Mortgage LLC is aware that the risk of unfair lending practices runs throughout the loan process. Northern Lakes Mortgage LLC is committed to implementing training and policies and procedures that protect against discriminatory practices at every level of the loan process, from application to loan satisfaction, and to taking corrective action should fair lending discrimination occur. If fair lending deficiencies are observed or appear in a team member’s job evaluation, the team member receives additional training or counseling in an effort to correct the deficiency. If the deficiency persists, the team member will be subject to more severe action, including termination.
It is the policy of Northern Lakes Mortgage LLC, before a loan is extended to an applicant, to consider the applicant’s ability to repay the mortgage loan, taking into consideration the applicant’s current and expected income, credit history, current obligations and employment status and to not base the decision on whether to extend credit to an applicant based on the applicants collateral or equity in the collateral without determining the applicants ability to repay the loan.
The Legal/Compliance Team reviews and approves, prior to distribution, marketing strategies directed to protected class applicants or minority communities to ensure compliance with fair lending laws. The Legal/Compliance Team also periodically reviews such existing marketing strategies to confirm that they remain in compliance with fair lending laws.
V. MONITORING & ASSESSMENT
Northern Lakes Mortgage LLC implements monitoring processes that review the lending practices of the institution, and individuals within the team, including the use of third party risk advisors. Northern Lakes Mortgage LLC monitoring program focuses on detecting deficiencies and ensuring that Northern Lakes Mortgage LLC personnel understand their duties and responsibilities under this plan and are carrying them out. The Quality Control Team performs regular audits of loan files to monitor data integrity for funded and non-funded loans and the results are provided to Senior Management and Risk Committee for review and corrective action if necessary. Loan files are monitored as part of the routine Quality Control (“QC”) process for conformance with these requirements. QC audit results are reviewed for conformance with the policy.
Oversight of monitoring and dissemination of the reporting is the responsibility of the CCO or his/her designee. The report is distributed to the Chief Executive Officer, or his/her designee, the Chief Risk Officer and the Risk Committee. In the event a variance is found, the CCO, or his/her designee, requests a meeting with the team members involved to review the results and take prompt and appropriate corrective action.
It is the policy of Northern Lakes Mortgage LLC to address complaints from applicants and former and existing borrowers (including complaints alleging or suggesting discrimination) in a prompt and fair manner and to ensure that unresolved complaints are elevated to the appropriate management team members on a timely basis for resolution.
Complaints are resolved in accordance with the Northern Lakes Mortgage LLC Complaint Policy.
Second Review of Loans
A second review is required of denied loans. Prior to denying a loan, the files are referred to a manager for a second review prior to formal denial of credit.
It is Northern Lakes Mortgage LLC policy to report a loan as withdrawn if a credit decision has not been made and the request is made by the applicant. A second review of the withdrawn application is performed on a periodic basis.
It is the policy of Northern Lakes Mortgage LLC for team members engaged in the mortgage loan origination process (including closers, underwriters, and managers) to complete fair lending training programs which are designed to educate team members on compliance with local, state, and federal fair lending laws, practices, and procedures. New team members receive a copy of this Policy. The acknowledgement contains a certification that the team member understands and commits to upholding the principals of the Fair Lending Policy, NY Executive Law 296-a and GENDA.
Team Member Services and/or the CCO or his/her designee are/is responsible for conducting fair lending update training for team members on an at least annual basis unless changes in the law necessitate more frequent training. The Compliance Team and/or Team Member Services are/is responsible for preparing the list of attendees and tracking attendance.
The Compliance Team, in conjunction with the Risk Committee, has oversight responsibility as to the content of the training programs. The CCO or his/her designee maintains a copy of the training materials.
DATE UPDATED: 05/01/2022