Leader Mortgage Company, Inc.'s policy is that the financial records of our customers and the relationships between Leader Mortgage and our customers are confidential and that the safekeeping of customer information is a priority of Leader Mortgage. 

We collect, retain and use information about our customers when we reasonably believe that it will help administer our business or provide products, services and other opportunities to them. We collect and retain information about our customers only for specific business purposes, and we will tell our customers why we are collecting and retaining it upon our customers' request unless prohibited by law from doing so. We use information to protect and administer our customer's records, accounts and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand our customers financial needs so that we can provide our customers with quality products and superior service. 

Purpose and Objectives
The purpose of this policy is to define specific principles for Leader Mortgage to follow in compliance   with customers' rights and existing laws as respects personal non-public information. 

•  No employee other than Leader Mortgage's designated representative(s) is authorized to divulge financial information or records of a customer to anyone outside Leader Mortgage. 
  
  
• It is the policy of Leader Mortgage Company, Inc. to cooperate with governmental agencies in their properly made, legitimate requests for information and only in compliance with the specific requirements of the Right to Financial Privacy Act. 
  
  
• It is the responsibility of each department manager to ensure that Leader Mortgage employees in their area understand the importance of confidentiality and customer privacy and receive training in responding to requests for information appropriate for the types of requests that may be received by that area. 

Expectation of Privacy
Leader Mortgage recognizes and respects the privacy expectations of our customers. Information about individual customers will be collected, retained and used only where Leader Mortgage reasonably believes it would be useful and allowed by law to administer Leader Mortgage's business and to provide products, services and other opportunities to its customers. Information, even of a general type, may not be disclosed except to the extent consistent with this Policy nor should such information be used in any manner to benefit Leader Mortgage employees or any other person. 

Account Information
Leader Mortgage's goal is that a customer's financial information is accurate, current and complete in accordance with reasonable Leader Mortgage standards. Leader Mortgage Company, Inc. will respond to requests by customers to correct inaccurate information in a timely manner. To the extent applicable, the handling of assertions of incorrect information shall be in compliance with state and federal Fair Credit Reporting requirements and applicable Federal Reserve Regulations (such as those that exist pursuant to Regulation E governing Electronic Funds Transfers). 

Restrictions on the Disclosure of Account Information
Leader Mortgage will not reveal confidential customer information to third parties except in the following instances: 

The information is provided to any affiliate of Leader Mortgage that may now exist or hereafter be established; 

• As necessary to effect, administer or enforce a transaction requested or authorized by the consumer; 
  
  
• To service or process a financial product or service requested or authorized by the consumer; 
  
  
• To protect the confidentiality or security of our customers records pertaining to the consumer, service, product or transaction; 
  
  
• To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability; 
  
  
• For required institutional risk control or for resolving consumer disputes or inquiries; 
  
  
• To persons holding a legal or beneficial interest relating to the consumer or to persons acting in a fiduciary or representative capacity on behalf of the consumer; 
  
  
• To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating our customers, persons that are assessing our customers compliance with industry standards; 
  
  
• To our customers attorneys, accountants and auditors; 
  
  
• To our attorneys, consultants, accountants and auditors;
  
  
• To the extent specifically permitted or required under other provisions of law and in accordance with the Right to Financial Privacy Act of 1978 (to law enforcement agencies, including government regulators); 
  
  
• To a consumer reporting agency in accordance with the Fair Credit Reporting Act; 
  
  
• In connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of a business or operating unit if the disclosure of nonpublic personal information concerns solely consumers of such business or unit; 
  
  
• To comply with Federal, State or local laws, rules and other applicable legal requirements; 
  
  
• To comply with a properly authorized civil, criminal or regulatory investigation, or subpoena or summons by Federal, State or local authorities; or 
  
  
• To respond to judicial process or government regulatory authorities having jurisdiction over our customers for examination, compliance or other purposes as authorized by law. 

We do not provide account or personal information to unaffiliated third parties for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services of those companies. However, we may also share information with unaffiliated companies when they assist us in providing products and services to our customers or we offer such products and services jointly. 

Access to Information
Leader Mortgage will maintain appropriate security standards and procedures regarding unauthorized access to customer information. Employee access to personally identifiable information will be limited to those with a business reason for knowing such information. If personally identifiable customer information is provided to a third party, Leader Mortgage will insist that the third party adhere to similar privacy principles that provide for keeping such information confidential.