Elevated Funding LLC Privacy Policy

ELEVATED FUNDING LLC does not currently share customer information with certain outside companies such as magazines or non-financial service providers.

ELEVATED FUNDING LLC is permitted by law to share customer information between its affiliates and third-party vendors for certain purposes. For example, information may be shared with service providers such as a loan servicer.

All vendors with which ELEVATED FUNDING LLC does business must sign a confidentiality agreement and are not permitted to use customer information for any purpose other than the reason stated in their contract. ELEVATED FUNDING LLC reserves the right, where permitted by law, to share customer information with outside companies if the customer has not opted out.

Safeguarding Customer Information

The ELEVATED FUNDING LLC Employee Code of Conduct requires that customer information remain confidential. Violation of this requirement by employees may result in disciplinary action, up to and including termination. In addition, ELEVATED FUNDING LLC may be subject to regulatory action, including administrative penalties.

Elevated Funding LLC Privacy Breach Policy

Privacy is a central element of ELEVATED FUNDING LLC’s consumer protection mission. Advances in computer technology have made it possible for detailed customer information to be compiled and shared more easily. While this has produced benefits for consumers and companies alike, it also requires stronger precautions against misuse.

All non-public private information, such as date of birth, Social Security number, account numbers, and amounts owing, is privileged information. All ELEVATED FUNDING LLC employees are under a specific legal duty to protect such information.

Procedures for Handling Policy Violations or Breaches

Oral Complaints

Oral complaints, no matter how seemingly unimportant, are to be taken seriously. Front-line staff who receive an oral complaint should seek to resolve the problem immediately, if possible. If staff cannot solve the problem immediately, they should offer to involve a manager.

If the complaint is being made on behalf of the consumer by an advocate, it must first be verified that the person has permission to speak for the consumer, especially if confidential information is involved. ELEVATED FUNDING LLC personnel should assume that the consumer’s explicit written permission is needed prior to discussing the complaint with the advocate.

After discussing the issue, the manager or staff member handling the complaint should suggest a course of action to resolve it. If the proposed action is acceptable, the staff member should confirm the agreement with the complainant and determine how the resolution will be communicated, such as through another meeting or by letter.

If the proposed action is not acceptable to the complainant, the staff member or manager should ask the complainant to submit the complaint in writing and elevate it to the Compliance Department for resolution.

Details of complaints should be recorded in the notes section of the Loan Origination System.

Written Complaints

When a complaint is received in writing, whether physically on a form or digitally, it should be forwarded to Compliance. Compliance should record it in the complaints database and send an acknowledgment letter within two working days. Compliance will then respond through the ELEVATED FUNDING LLC complaint resolution process.

If necessary, further details should be obtained from the complainant. If the complaint is not made directly by the consumer but on the consumer’s behalf, written consent from the consumer must be obtained.

If the complaint raises potentially serious matters, advice should be sought from General Counsel. If a staff member becomes aware of legal action against ELEVATED FUNDING LLC, they should contact Senior Management or General Counsel immediately and cease dealing directly with the customer or advocate.

Immediately upon receipt of a written complaint, ELEVATED FUNDING LLC will conduct an investigation and, within 28 days, should be in a position to provide a full explanation to the complainant, either in writing or by arranging a meeting with the individuals concerned. If the issues are too complex to complete within 28 days, the complainant should be informed of the delay.

The outcomes of the investigation and any letters or meetings with the complainant should be recorded on the appropriate documentation, and any shortcomings in company procedures should be identified and communicated to Compliance.

Privacy Breaches

Any individual who suspects that a theft, breach, or exposure of ELEVATED FUNDING LLC protected or sensitive data has occurred must immediately provide a description of what occurred via email to Senior Management or Compliance.

ELEVATED FUNDING LLC will investigate all reported thefts, data breaches, and exposures to confirm whether an incident occurred. If confirmed, the company will follow the appropriate procedure depending on the class of data involved.

If the incident is a suspected theft, legal counsel shall also be contacted. Counsel will determine whether a local law enforcement agency should be contacted based on the location and details of the incident.

As soon as a confirmed theft, data breach, or exposure involving ELEVATED FUNDING LLC protected data or sensitive consumer information is identified, the process of removing all access to that resource will begin as soon as possible.

Right to Financial Privacy Act (RFPA)

The federal government and several states have enacted financial privacy laws. The Right to Financial Privacy Act (RFPA) limits federal and state government access to a borrower’s financial records held by a financial institution.

The Act obligates financial institutions to preserve borrower financial privacy. A financial record is defined as the original, a copy, or information derived from a record pertaining to the borrower’s financial relationship with the institution.

Generally, ELEVATED FUNDING LLC will not release financial information without the express written consent of the borrower or appropriate legal process, such as a subpoena, summons, or search warrant. All legal processes must be forwarded to Senior Management and legal counsel.

Consumer Privacy

As consumer privacy issues continue to receive increased attention from the public and the news media, it is important that all ELEVATED FUNDING LLC employees understand the company’s policies that protect sensitive customer information.

ELEVATED FUNDING LLC considers customer privacy concerns to be of the utmost importance. The company will do whatever is necessary to ensure the information received from customers is handled with maximum care and in accordance with applicable law.

Accordingly, ELEVATED FUNDING LLC has implemented specific policies and procedures governing:

• the use, collection, and retention of customer information

• employee access to customer information

• sharing sensitive borrower information

• various requests for information

Gramm-Leach-Bliley Act

In addition to the Right to Financial Privacy Act, the Gramm-Leach-Bliley Act (GLBA) was passed in November 1999 to further protect consumer privacy. Title V of GLBA requires each financial institution to disclose its privacy policy to customers and provide borrowers with the ability to opt out of sharing their nonpublic personal information with third parties and affiliates for certain purposes.

This communication to customers must take place when they begin their relationship with the financial institution and when they open subsequent relationships. A disclosure of the privacy policy must also be provided annually. These disclosures must explain what information is gathered, how it is gathered, and how the financial institution will use the information.

The Gramm-Leach-Bliley Act serves many purposes. Not only must financial institutions disclose their privacy policies, but customers must also be given the opportunity to opt out, or restrict, the information shared with third parties or affiliates for certain purposes. Some sharing remains necessary to conduct transactions for the customer. After opting out, information may still be shared where necessary to do business. For example, a check-printing vendor may receive limited information needed to complete a transaction and nothing more.

To comply with consumer privacy requirements and support an efficient opt-out process for customers and employees, ELEVATED FUNDING LLC has adopted a company-wide Privacy Policy. It applies to both consumers and business customers.

Customers may opt out by checking the box on electronic notices or by sending a written request to the Director of Operations. This is intended to make the process as simple as possible for the customer.

Additionally, all vendors with which ELEVATED FUNDING LLC does business must have confidentiality agreements in place to protect customer information.

Consumers receive the ELEVATED FUNDING LLC Privacy Policy with documents and disclosures and must be given the opportunity to opt out at the time of closing their mortgage, since this is considered the time at which the customer begins their relationship with ELEVATED FUNDING LLC.