Flagstar Bank is committed to serving all borrowers equally, without regard
to an individual's race, color, national origin, religion, sex, familial status or handicap.
As such, it is Flagstar's policy to issue all conditional commitments (to purchase a loan)
without regard to a borrower's race, color, national origin, religion, sex, familial status
With the goal of Fair Lending in mind, it is also our policy to promote Fair Lending practices to our
entire wholesale customer base. Though Flagstar Bank does not dictate how a wholesale customer prices a loan or charges
fees to a borrower, we must emphasize the critical nature of supporting sound Fair Lending practices.
Flagstar Bank urges all of our wholesale customers to develop fair lending procedures that provide
controls to determine and guard against originating loans that are in any way biased based on a borrower's race, color,
national origin, religion, sex, familial status or handicap.
Bias is not restricted to merely whether or not a borrower receives a loan. Bias may also be
demonstrated by analyzing rates and fees charged to borrowers of a specific group. In an effort to ensure that our
wholesale customer base is compliant with the Fair Housing Act, Flagstar performs regular post-closing reviews to
determine if any borrower treatment or pricing disparity exists for borrowers in a specific group (as outlined by the
Fair Housing Act).
By reviewing the rates/fees charged on closed loans purchased from our wholesale customer base, our
goal is to verify whether any disparities exist. If Flagstar determines that disparities do exist for a specific wholesale
customer, we may exercise our right to cease conducting business with a specific wholesale customer.
We would also like to emphasize that Fair lending laws do not focus on a lender's "intent." We believe
that all wholesale customers "intend" to provide borrowers with loans. Rather than focus on intent, compliance with the
Fair Housing Act requires our wholesale customer base to look at their loans and analyze whether all borrower groups are
priced/charged and treated equitably.
Though Flagstar does analyze rates and fees charged by our wholesale customer base, we would like to
emphasize that this practice will not protect you from being pulled into litigation for non compliance with the Fair
Housing Act. The best way to protect your business is to adopt sound and comprehensive fair lending procedures. By doing
so, we work together in our common goal of Fair Lending for all borrowers.
For your convenience, we have provided HUD's language on Fair Housing as it pertains to our industry: