Advertising Policy and Procedure

As an originator, you are required to be informed and knowledgeable about all federal and state advertising regulations so please review these guidelines carefully. All advertising to the general public must be done in the name of C2 Financial Corporation and MUST be pre-approved by the company (If you are advertising only to realtors, you do not need to submit for approval). Additionally all websites must be reviewed annually and approved each year and if you make changes to your website you MUST submit it for review to ensure the changes are compliant.

Our advertising philosophy is very simple:
If your ad could be interpreted as misleading by the public or a state organization, we’re going to ask you to revise it.

Please use the guidelines and procedures laid out below to ensure your ad is compliant and to assist us in our review.

APPROVAL PROCEDURE:

support@americasloancenter.com

a. Remember a website is considered an advertisement and is subject to this policy and procedure.

RECORD RETENTION

You, the loan originator, must maintain copies of all advertisements for a period of 3 years from the date of dissemination and all back up documentation used to create such advertisement:

This means you must keep the following:
1) Copies of actual advertisements sent to consumers 1. If it is a Radio or TV ad, this includes the script and a video or recorded copy of the final product.
2) Rate sheets
3) Correspondence with lenders utilized in creating the advertisement
4) Written approval of advertisement from C2

C2 may request copies of these documents from time to time to ensure that you are complying with this record retention requirement. C2 will also maintain copies of all advertisements submitted for review and approval.

AD GUIDELINES:

The following guidelines must be followed when engaging in any type of advertising (i.e. websites, print ads, media ads, etc.). These guidelines incorporate both state and federal (Mortgage Acts and Practices- Advertising 12 CFR part 1014 (aka Reg. N)) advertising regulations.

Additionally, at the end of this document there is a “Sample” written advertisement showing key features, i.e. license number placement, disclaimer, etc. to be used in a print ad.

1) GENERAL DISCLAIMER
The following disclaimer must be included on ALL ads in California:

This licensee is performing acts for which a real estate license is required. C2 Financial Corporation is licensed by the California Bureau of Real Estate, Broker # 01821025; NMLS # 135622. Loan approval is not guaranteed and is subject to lender review of information. Loan is only approved when lender has issued approval in writing. Specified rates may not be available for all borrowers. Rate subject to change with market conditions. C2 Financial Corporation is an Equal Opportunity Mortgage Broker/Lender. (Add this for website disclaimer: The services referred to herein are not available to persons located outside the state of California.)

If you are advertising outside of California, a similar disclaimer would be used, but will have slight variation. Email support@americasloancenter.com for disclaimer.

2) VA AND FHA DISCLAIMERS
a. VA/FHA: If you indicate that C2 Financial Corporation is VA or FHA approved, use the following language:

C2 Financial Corporation is approved to originate VA and FHA loans, and has the ability to broker such loans to VA and FHA approved lenders. C2 Financial Corporation is not acting on behalf of or at the direction of HUD/FHA or the VA.

b. VA/FHA LOGOS: You can use the VA and FHA logos on advertisements as we are approved, but if you use such logos, in the disclaimer at the bottom of your ad you must include the following language:

C2 Financial Corporation is approved by FHA as an agent and has the ability to broker FHA loans to FHA Approved Lenders. Or C2 Financial Corporation is approved to originate VA loans, and has the ability to broker such loans to VA approved lenders. C2 Financial Corporation is not acting on behalf of or at the direction of HUD/FHA or the VA.

3) GOVERNMENT AFFILIATION

It is strictly prohibited to give any indication that you are affiliated with the government or any government agency on your advertisements. You cannot state that the government or a governmental agency has approved your advertisement or is any way associated with C2 or yourself.

This is false advertising and will be strictly enforced. Specifically, please be very careful to avoid governmental association on advertisements with regards to reverse mortgage products, even if the program is backed by a government program, C2 is not affiliated with such program and it is prohibited to represent this.

4) WEBSITES

The domain name of your website, i.e. www.c2financialcorp.com/lo, must be either a C2 issued website with the company domain or it can be your full licensed name. All other domain names are prohibited. You cannot use a dba that is a company name, or a nickname, or a variation of your licensed name, nothing is allowed other than your licensed name as is registered with the BRE/State/NMLS.

The only exception to the above is for BRE licensed Brokers, if you have a website that is registered as a dba under your Broker license, you can maintain this website/domain, so long as it follows all BRE registration and advertising guidelines.

5) WEBSITE DISCLAIMER

Anything posted on your website MUST contain the following disclaimer:

The services referred to herein are not available to persons located outside the state of . Example: If you are only licensed in California, your disclaimer would say: The services referred to herein are not available to persons located outside the state of California.

6) NMLS CONSUMER ACCESS LINK ON ALL WEBSITES

You must have a link to the NMLS Consumer Access website on your website. This website is:

www.nmlsconsumeraccess.org
7) LICENSE #s AND PLACEMENT

a. All License #s: Your license number and C2 Financial Corporations license number must be included on all ads, both state license # and the NMLS number.

b. Placement: The Loan Officers BRE and NMLS license numbers must be included in the body of the advertisement, not in the disclaimer or 'fine print' section. Additionally the license numbers need to be located closely following the MLO name on the advertisement.

c. Title: You must list your title or an indicator such as "Loan Originator", "Loan Consultant, "Loan Officer", etc. in the full text of the ad, not just in the disclaimer section.

8 FULL NAME

All advertising must be under the company's FULL NAME, C2 Financial Corporation. You cannot abbreviate the company name). Additionally, the originator must use their name as registered with NMLS.

9 SOCIAL MEDIAM

Social Media is a form of advertising. If you have a personal Facebook, LinkedIn, Instagram, MySpace, YouTube, blog page, etc. and you have chosen to list your occupation and/or C2 Financial Corporation, your social media page MUST comply with all state and federal advertising guidelines and with this policy.

You must submit your social media page for review, you must submit any changes for review and you must ensure compliance with this policy. Failure to do so may result in discipline, up to and including termination.

If you utilize social media solely for personal, non-business related purposes, please ensure that there is no reference to your occupation, C2 Financial or the mortgage industry on your pages.

10 INDUSTRY WEBSITES:

If you claim a link on a website such as Yelp, Zillow, etc. these sites are also advertising and you must ensure all information provided is accurate and in compliance, i.e. licensing numbers and information are provided and correct, the company name is complete, your name matches the NMLS, etc.

11 BUSINESS CARDS

Business cards are advertisements. You must list the following on all business cards:

a. Full Name, as it is listed in the NMLS (you cannot use a nick name, abbreviation, etc. if you would like to use a different name, you can list this below in quotations showing it is your preferred name, but your full legal name as listed in the NMLS must be on your cards)

b. Full Company Name- you must use the companies full name.

c. All License Numbers- your license numbers (state and NMLS) and C2's license numbers (state and NMLS) must be listed.

d. Title- You must have "Residential Mortgage Loan Originator" or "RMLO" on your card either in connection with another desired title or as your only title.

e. Branch Address- You must list the branch with which you are affiliated in the NMLS, if you operate out of corporate, this must be listed, if you have a licensed branch, this address may be listed.

12 BRANCH ADDRESS

If an address is listed it must be a branch address registered with the state and NMLS. If you are operating from a home office, you cannot list your home office address on the advertisement unless your home is licensed and registered with the state and NMLS.

13 MISLEADING/DECEPTIVE STRICTLY PROHIBITED

Anything that could be construed as misleading, false or deceptive is prohibited, and in addition to text, all pictures, size of texts, formatting, emphasis on certain terms/items, etc. will be considered. If it could create a false impression, it is not allowed regardless of how close it follows the guidelines.

14 BANKING

Unless you are advertising for Banking, do not represent that C2 Financial Corporation is a lender. This includes advertising VA, FHA and other government loans. Ensure that there is no reference to C2 Financial Corporation and underwriting of loans or other lender references.Please remember that C2 is NOT licensed as a Lender in all states we operate, if you are licensed in one of the states that we do not hold a lender license, please be sure not to advertise as such, even if you are located in a state where you can do banking. Websites are not controlled by state and can be viewed globally. Therefore they need to comply with all state requirements, not just your home state.

15 SPECIFIC TERMS/TIME LIMITATION

If you choose to use specific terms, you must only state those terms that the lender (creditor) is actually offering, in order to prove this you must maintain the rate sheets in which the terms are coming off of and provide this along with the advertising approval form. If certain terms are only available for a certain amount of time, this also must be stated.

16 RATE AND APR

If you include an interest rate of finance charge you must also include APR. The APR must be disclosed with equal prominence in the advertisement, i.e. cannot hide APR in fine print.

17) AVOID FINE PRINT

Avoid using fine print, separate statements or other "qualifying language or formats" to correct a potentially misleading headline. Say what you mean, do not try to grab attention with a misleading headline with fine print to correct it. This is not allowed.

18) PROHIBITED PHRASES

You may not use the following phrases (or anything similar or that could be construed as such). If you have questions about language you would like to use, please ask:

Your loan is guaranteed
- No Cost Loan
- You can skip mortgage payments
- No points, no fee loan
- We guarantee the lowest rate, or Lowest Rates Available
- We guarantee a specific rate
- We pay closing costs
- "We have the best rates", or "we can offer you the best loan", or "have better terms", etc. (anything that is a superlative or comparative is prohibited as is ambiguous and misleading and cannot be proven)
Any term that cannot be substantiated is prohibited, i.e. "Leading Mortgage Company"

As a reminder, these phrases cannot be located on a website or social media page either, as both are also advertising.

19) If there is a representation that loans are available to a maximum percentage of market value, you must state how the market value will be determined.

20) No implication that the borrower will be able to obtain a loan without deductions from principal or payment of commissions, costs or expenses.

21) If you are going to advertise a rate that can be obtained including YSP you need to adequately explain that the closing costs are effectively being financed and therefore still being paid by the borrower. Detailed explanations are necessary.

22) No representation that a loan can be approved by telephone.

23) No representation that credit rating or other personal financial data won't be a factor unless this is a true statement.

24) No misleading advertising of Fixed Rates if there is the possibility of the rate adjusting.

25) If the APR is disclosed and is subject to increase after consummation, this must be disclosed although the amount of the increase, the limits and the effect on the payment schedule does NOT need to be disclosed.

26) The following are "trigger terms":

- amount or percentage of any down payment
- amount of any one payment
- amount of any finance charge
- # of payments or period of repayment

If any of these "trigger terms" above appear in the advertisement, then the following terms must also appear as applicable:

- Amount or percentage of down payment - Terms of repayment (ex: $359 for 48 months) which reflect the repayment obligations over the full term of the loan including balloon payment
- APR using that term and if the rate may be increased after consummation

27) If you include specific payment amount, i.e. $2000 per month, you must include the following in equally prominent disclosures:

a. Term of the loan,
b. Principal loan amount,
c. Interest rate,
d. Annual percentage rate (APR), and/or
e. If there is an adjustable rate, you must disclose how long the initial interest rate is in effect, how often and how much the interest rate and/or payments can change and if there is a potential for negative amortization, and/or
f. If there is a balloon payment the number, amount and period of payments scheduled to date of maturity amount of balloon payment, if applicable.

28) If you include a representation of a specific installment payment, interest rate, APR or other provision of a loan, must state whether it is available for first loans, junior loans or both first and junior loans.

29) Adjustable Rate Loans: You must state how long the initial interest rate will be in effect, how often the rates may adjust and by how much. Also, if there is the potential for negative amortization (deferred interest), you must conspicuously disclose this.

30) Non Traditional and sub-prime loans that are advertised have very strict requirements. If you desire to advertise one of these types of loans it must comply with both state and federal strict requirements. Therefore, please check with compliance before creating this advertisement, failure to do so will result in disciplinary action.

31) Do not state that:

a. The borrowers are pre-approved or that their property is pre-approved;
b. That the loans are insured;
c. That poor or no credit is acceptable;
d. No equity is required or no appraisal is required, unless the advertisement makes clear the conditions under which these are not required and make sure to maintain the rate sheets and lender information to support these products;

32) Advertising that looks like a check is prohibited.

33) You cannot solicit borrower's using a prerecorded message machine, regardless of whether this borrower is a past client.

34) All information posted on a website qualifies as advertising. All website information must be reviewed by management prior to posting.

a. Ensure that your license number is listed on every page of the site
b. The only websites that may be used must have a domain of C2 Financial Corporation unless you have a C2 approved dba that has been registered with the county and the BRE.

35) If you will be using another lender's name on your advertising, such as in circumstances where you stating in a letter the consumer's current lender and balance, etc, the following guidelines apply:

i) The advertisement/solicitation must clearly and conspicuously state: "Company Name and _______________ (Name of LO) are not sponsored by or affiliated with (the lender) and the advertisement/solicitation is not authorized by (the lender) named in this advertisement/solicitation."
ii) You can only include a consumer's loan number if the advertisement clearly and conspicuously states: "The consumer's loan information was not provided by (the lender)".
iii) You must make the above statements in close proximity to and in the same font or larger than the one used in the rest of the advertisement/solicitation. And this must be included on an envelope used or showing through the window of the envelope of the advertisement/solicitation. iv) The advertisement/solicitation must not cause a reasonable person to be confused, mistaken, or deceived initially or otherwise as to the lenders affiliation with Company and the person (the LO advertising) using the lender's name or the lender's approval or endorsement of the advertisement/solicitation.

36) Broadcast faxing is illegal and prohibited; if you are going to send anything by fax you must have permission.

37) Spam emails are illegal and prohibited; if you are going to send anything by email you must have permission.

History:

Date	Drafted By	Version/Notes
Jan 1, 2013	Noelle Pepper	V. 1
Dec 26, 2013	Noelle Pepper	V. 2
Sept. 1, 2014, finalized 10/27/14	Noelle Pepper	V. 3

SAMPLE AD – Showing License #s, Title, and standard disclaimers

Borrower
Address
City, St ZIP

DATE

Dear Homeowner:

According to our records, we may be able to help you refinance your loan into a lower interest rate with a lower monthly payment, etc, etc etc.

Currently, we have a 4.5% rate (4.55% APR) program which many borrowers are able to qualify for.

Please contact us for more information
Sincerely,
Joe Smith
Senior Loan Consultant
BRE # 1234567, NMLS # 87654

C2 Financial Corporation is licensed by the California Bureau of Real Estate, Broker # 01821025, NMLS # 135622. This licensee is performing acts for which a real estate license is required. C2 Financial Corporation is an Equal Housing Mortgage Broker/Lender. Loan approval is not guaranteed and is subject to lender review of information. Loan is only approved when lender has issued approval in writing. Specified rates may not be available for all borrowers. Rate subject to change with market conditions