Regulation B

August 2017

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FWB’s Philosophy

FWB’s policy is to treat "all individuals fairly" in every aspect of the lending process; from advertising to collection

practices.

It is the philosophy of the Bank to look for ways to extend loans to credit worthy individuals.

The act applies to all loans and credits with no exceptions, meaning the law applies to Business and all Consumer Loans.

The Law applies whether the applicant is an individual, a corporation, a partnership or any other entity.

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General Guidelines

Discrimination is prohibited in extending credit.

FWB carefully grants or decline credit in relation to the potential borrower's credit worthiness.

FWB will grant or deny credit to potential borrowers without regard to:

• Race

• Color

• Religion

• National Origin

• Sex

• Age

• Receipt of income from public assistance programs

• Good faith exercises of right under the Consumer Protection Act of 1968

• Handicap

• Familial Status

• Marital status – in making credit decisions, do not treat joint applicants differently based on the

existence, the absence, or the possibility of a marital relationship between two parties.

FWB documents our continuing compliance with this policy of non-discrimination.

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Completion of Applications

On every application for ANY credit, check to see:

that the Regulation B Box is accurately completed;

that the application is dated;

that the Loan Purpose is stated;

that the Loan Amount is noted; and,

that the manner in which the application was received is marked.

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Residential Mortgage Applications

On Residential Mortgage Applications

make sure the Government Monitoring Section

is completed properly for HMDA reporting

using form 710A

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Form 710A - Example

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Reg B Box Addendum

Applicant's Request for Credit

If the Reg B Box has been

incorrectly completed

or information has changed

or the application date exceeds 30 days

(for approved loans only)

the Regulation B Addendum

may be used to correct/add information

to this section of the application

Remember:

Reg B information

is be completed by the customer.

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Sample of Reg B

Addendum

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Consumer Request for Credit

Applicant's Name:

Address:

City, State, Zip:

On MM/DD/YY a loan application with FinWise Bank was completed, I would like to change the following areas:

I am applying for: a Loan a Line of Credit

In the amount of: the requested term will be

For the purpose of:

I am applying for this credit (Mark only one)

ALONE without a co-signature or guaranty of my spouse, a relative, or any other person or entity.

WITH the co-signature or guaranty of one or more persons or entities (including any existing Guarantors).

Important Information about Procedures for Opening a New Account. To help the government fight the funding of terrorism and money laundering activities,

Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you:

When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see

your driver’s license or other identifying documents.

I understand I will be responsible for paying any applicable commitment fees or other charges. There has been no adverse change in my financial condition as

disclosed to you on my most recent financial statement or credit application.

Signed: Date:

Signed: Date:

How was Application

Received — (X) In Person By Mail By Telephone By Electronic Medium By Internet

Spousal Signatures

The Bank will not require the signature of an applicant’s spouse or

any other person, on any promissory instrument if the applicant

qualifies under the Bank’s standards of creditworthiness for the

amount and terms of the credit requested.

If the applicant does not qualify,

the Bank may ask for a cosigner/guarantor,

but will not specify who that cosigner/guarantor shall be.

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Notification of Applicants – Approvals

FWB is required to notify applicants of our decision

to either make the loan request or decline the

loan request within 30 days of the application date.

Notification will be made as shown

on the following 5 slides.

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Notification of Applicants

Approvals

On all credit requests that are approved.

The customer should promptly be notified that their loan request has been approved.

Inform them of any requirements needed to fulfill their part of the credit decision, i.e., insurance binder, title to a vehicle,

collateralization of the loan, etc.

A loan closing time should be set with the customer and documents prepared.

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Notification of Applicants

Declines

On all credit requests that are declined for any reason.

Notify the customer of adverse action within 30 days of the application date

Complete an Adverse Action Letter for all persons listed on the application. When sending decline letters to multiple applicants, each notice must be put into a separate envelope.

All applicable decline reasons should be marked (up to 4).

If in doubt as to the reason for declining the loan, please contact the CLO.

Input the correct address of any credit reporting agency used in determining credit worthiness, whether or not the credit report was used as a basis for the

credit decline decision.

Co-signers should be provided a separate letter.

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Notification of Applicants

IncompleteOn requests that require further information to complete the loan file.

When an application requires further information that has previously been requested from the applicant, and that information has not been provided, notify

the applicant within 30 days of application date, of the items required to complete the request for credit. Use an Adverse Action Notice.

Complete as follows:

Under "Description of Adverse Action Taken" enter:

Further Information Required

Then enter the item(s) required to make the appropriate credit decision.Example: To further consider your application for credit, Utah Community Bank requires:

Tax Statements, a Financial Statement, 4 consecutive pay stubs, etc.

Send the letter to the customer within 30 days.

If the customer provides the required information, the credit approval process may continue. Incidentally, a new 30 day period is started upon receipt of the

required items. If, after further review, the credit request is declined, a new decline letter must be prepared and sent to the customer.

If the items are not provided, the file, along with the copy of the letter are placed in the turndown files, no further decline action is required.

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Notification of Applicants

Approved Not Closed

On all credit requests that are approved, but not closed.

When a request for credit is approved, but the applicant decides not to obtain the loan or gets financing

elsewhere, the loan officer need only note at the top right corner of the loan application the following:

Application Approved

Date (Make sure this is within the 30 day period)

Officer's Initials

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Notification of Applicants

Business Credits Declined

On all Business credit requests that are declined.

Business credit declines may be verbal.

Please observe the following scenario:

Contact the Business applicant and

advise of the reasons for denial.

Make a note of the following information

on the upper right corner of the application:

That the request was denied.

The name of the individual contacted.

The date of the notification. (Make sure this is within the 30 day period).

The initials of the loan officer.

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Second Look Policy

When adverse action is taken, FWB’s policy requires the Compliance Officer review the request looking for consistent lending practices.

A copy of the denial letter will be initialed by the C.O. if

there is agreement with the original denial decision.

If the original denial decision is to be reversed or a countered,

the Chief Lending Officer will visit with the Lending Officer to

discuss the concerns and have the originating Lending Officer contact

the loan applicant to either make the loan request or present a counter offer.

This review policy will further advance FWB’s

commitment to consistent, fair lending practices.

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