Customer Privacy Statement

Homeowners Financial Group USA, LLC (or HFG or “us” or “we”) is committed to protecting the privacy and security of our customers’ non-public personal information and ensuring the accuracy of that information. We collect and maintain information about you to enable us to complete your loan transaction, conduct our business in a manner consistent with federal and state laws and regulations, provide you with information and offers on products to meet your future needs, and satisfy legal requirements.

This Statement principally governs HFG’s use of non-public personal information. In this Statement, non-public personal information generally means information obtained in connection with a financial product or service that is identified with you and that is not obtainable from a public source. We will give you a new Customer Privacy Statement whenever we change our privacy policies or practices.

This Customer Privacy Statement ("Statement") describes and explains how:

• HFG collects and uses your non-public personal information;
• HFG maintains the confidentiality and accuracy of your non-public personal information;
• You can limit the communication of your non-public personal information by HFG; and
• You can verify the accuracy of information regarding your transactions with HFG.

Non-Public Personal Information We Obtain and and How We Obtain It. In conducting our business, we collect and maintain various types of non-public personal information about our customers. We collect this information to provide you with products you have required and to service your requests efficiently and accurately. If we are unable to obtain this information from you, we may be prevented from providing you with a service and/or may be compelled to terminate a service that we are currently providing you. The types of non-public personal information we collect and maintain include:

Information that we receive directly from you in applications and other forms that you deliver to us, and from our verbal or written communications with you. This may include information such as your address, telephone number, account numbers, Social Security numbers, assets, incomes, debt, etc.

Information we compile from your transactions or experiences with HFG. This may include information such as your account balances, payment history, etc.

Information we receive from non-affiliated third parties regarding your transactions or relationships with them or to verify information you have given us. This may include information such as your employment history, loan and/or credit payment history, your loan or credit card balances, your property insurance coverage, appraisals or your residence, etc.

Information we receive from credit bureaus regarding your credit history and credit worthiness (such as the amount of your total debt, your payment history, etc).

Information we obtain from public sources. This may include information contained in federal, state, and local records such as recorded liens on your property, real estate taxes and assessments, tax liens, etc.

We may also obtain demographic or other information about you that is not assembled for the purpose of determining your eligibility for credit.

How We Use Your Non-Public Personal Information and How We Share That Information.

We use your non-public personal information only as permitted by applicable law. We may disclose all of the non-public personal information that we collect about you, as described below. The following summarizes the ways in which HFG uses such information and with whom HFG may share such information:

With Unaffiliated Third Parties. As permitted by law, HFG will sometimes disclose your non-public personal information to companies or entites unaffiliated with HFG. Examples of when this might occur include the following:

Third Party Services. We may disclose your non-public personal information to companies that provide services to HFG, such as data storage and imaging companies as well as Home Mortgage Disclosure Act compilers.

Lenders, Title Companies, Escrow Companies, etc. We may disclose your non-public personal information to other lenders, title companies, escrow companies, and other service providrs necessary to facilitate your loan transaction.

Non-profit Agencies. We may disclose your non-public personal information to non-profit agencies providing homeowners assistance programs if you have applied to participate in such a program in connection with your loan transaction.

Legal Requirements. We may at times be required to disclose your non-public personal information to comply with subpoenas, court orders, and legal reporting requirements.

Written Consent. We may disclose your non-public personal information with your written consent, including when you give someone power of attorney or other authorization to act on your behalf.

Business Transfers. We may disclose your non-public personal information in connection with a proposed or actual sale or transfer of your loan to another company.

Fraud Protection, Etc. We may disclose your non-public personal information to prevent fraud and unauthorized transaction, to resolve customer disputes, and as necessary to HFG’s regulators, attorneys, accountants, and auditors.

Other Purposes. We may also disclose all the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements. As described in Section 3, below, if you are a Resident of California, you may limit our disclosure of your information with these nonaffiliated financial institutions.

Protecting Personal Customer Information From Unauthorized Access. Safeguarding your non-public personal information is important to HFG. We maintain systems, polices and procedures designed to protect your non-public personal information from being accessed by unauthorized persons. We limit employee access to non-public personal information to those with a legitimate business reason for such access. We train our employees in our privacy policy and procedures, and hold them accountable for adhering to our privacy policy and procedures.

Our Former Customers.

After you are no longer a customer of HFG, we will continue to treat the non-public personal information we have about you as if you were still our customer.

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