The Claxton Bank (“TCB”) is committed to providing credit opportunities in the communities in which we conduct business. We recognize our responsibility for ensuring members of these communities receive equal access to our products and services, which is why it is the policy of The Claxton Bank to comply both to the letter and spirit of fair and responsible lending laws. TCB’s fair treatment of current and potential customers is a vital part of our overall commitment to maintaining the highest standard of corporate responsibility. This extends to every aspect of a credit transaction, including but not limited to, advertisement, pre-application inquiries, loan disbursements, and loan servicing. It is the Bank’s policy to treat all consumers consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable, and consistent manner. We will also communicate our fair lending policy to all of our brokers and correspondents.

Fair Lending Laws

Fair lending laws in the United States require equitable treatment of all credit applicants without regard to race, sex, gender identity, sexual orientation, color, national origin, religion, age, marital status, disability, familial status, the fact that all or part of the applicant’s income derives from public assistance programs, or to the fact that the applicant has in good faith exercised any right under the Consumer Credit Protection Act. Denying any person equal access to credit and economic opportunities is immoral and will not be tolerated in our company. We will help meet the credit needs of the communities in which we operate, including low-income and moderate-income neighborhoods.

Equal Credit Opportunity Act (ECOA)

Under the Equal Credit Opportunity Act (ECOA), it is illegal to discriminate in any credit transaction on the basis of race, color, religion, national origin, sex, gender identity, marital status, age (provided the applicant has the capacity to contract), applicant’s receipt of public assistance income, and/or the applicant’s exercise of any right under the Consumer Credit Protection Act, affects every phase of the lending process. The provisions of the ECOA make it illegal to discourage an applicant, decline a request for, or terminate a loan based on any of the factors listed above.

Fair Housing Act (FHA)

The Fair Housing Act prohibits discrimination in the sale, rental, and financing of property based on disability, familial status, gender, national origin, race, religion, or sexual orientation and ensures the Bank’s adherence to the provisions prohibiting discriminatory practices against applicants applying for real estate loans for the purchase, construction, improvement, repair, or maintenance of a dwelling, or loans secured by a dwelling.

Americans With Disabilities Act (ADA)

The Americans with Disabilities Act (ADA) prohibits discrimination against qualified individuals with disabilities. It assures that protected individuals have equal access to goods and services offered by private businesses.

Civil Rights Act of 1886

This law guarantees equal rights to purchase real estate and personal property to all people, regardless of race.

Community Reinvestment Act

The Community Reinvestment Act ensures that the Bank is meeting the credit needs of the communities which it serves within its assessment area.

Fair Credit Reporting Act

Under the Fair Credit Reporting Act, it is the Bank’s policy to prevent undue invasion of a consumer’s right to privacy in the process of collecting information and disseminating credit reports.

Fair Lending Regulatory and Enforcement Agencies

Our Regulatory Agencies

Regulatory agencies have a broad range of powers in evaluating the compliance of lenders. The Claxton Bank undergoes routine examinations to ensure that our policies and procedures are in compliance with our own internal policies, industry standards and best practices, and state and federal regulations. Our fair lending regulatory agencies include the:

• Consumer Financial Protection Bureau (CFPB)
• Federal Reserve Board (FRB)
• Federal Deposit Insurance Corporation (FDIC)
• Federal Trade Commission (FTC)
• Georgia Department of Banking and Finance (DBF)

Enforcement Agencies

Enforcement agencies investigate alleged Fair Lending violations, and include the:

• Department of Justice (DOJ)
• Department of Housing and Urban Development (HUD)