AMERICAN MORTGAGE

SERVICE, INC.

CUSTOMER COMPLAINT POLICY

It is the policy of our company to respond to customer complaints, disputes and issues immediately, to take each complaint seriously, to investigate each complaint however small it is - immediately and to take remedial actions swiftly.

As soon as a complaint is received, it is documented and is logged into a special log. The complaint is sent directly to the Customer Complaint Officer or designate, in order to take action. Our Customer Complaint Officer is Shannon Robinson.

All complaints and records of complaints are kept in a special complaints binder along with all the Customer Complaint Officer's Quality Control Files and other written policies so employees can easily access them and use them to provide better customer service. Reports on complaints are reviewed during the Customer Complaint Officer's meetings with our Board. We are focused on providing financial products and services to all customers in compliance with all Federal and State regulatory policies including but not limited to consumer protection, fair lending and civil rights laws.
In the event a complaint needs to be filed with us the complaining entity or person may:
  • Contact our Customer Complaint Officer at the number above.
  • Notify our Customer Complaint Officer in writing via email.
  • Write a traditional letter to us at the address below.

The complaint should be encouraged to be submitted in writing, and should include the following information:
  • The name, address, and telephone number of the complainant.
  • A description of the act or practice that is thought to be unfair or deceptive, or in violating of existing law or regulation, including all relevant facts.

Response to a complaint sent directly to us will typically be provided before the end of thirty (30) day period from the date that we received the complaint.
In the event a complaint is not resolved to your satisfaction you may contact the Consumer Financial Protection Bureau at http://www.consumerfinance.gov/complaint
Accepted for the Company:
Clayth Name 114/21 Date
Address for traditional letters:
American Mortgage Services, Inc 1000 N, Ashley Drive, Ste 1020 Tampa, Florida 33602 Office: (813) 831-9330 www.wegetitclosed.com NMLS ID: 259805
Name Date
Compliance Services USA (C) 2021 Book One Operating Policies and Procedures Licensed feytor y seisthuseghyanghy2022

FOR WEB SITE


It is the policy of our company to respond to customer complaints, disputes and issues immediately, to take each complaint seriously, to investigate each complaint however small it is - immediately and to take remedial actions swiftly.
As soon as a complaint is received, it is documented and is logged into a special log. The complaint is sent directly to the Customer Complaint Officer or his designate, in order to take action.
All complaints and records of complaints are kept in a special complaints binder along with all the Customer Complaint Officer's Quality Control Files and other written policies so employees can easily access them and use them to provide better customer service. Reports on complaints are reviewed during the Customer Complaint Officer's meetings with our Board. We are focused on providing financial products and services to all customers in compliance with all Federal and State regulatory policies including but not limited to consumer protection, fair lending and civil rights laws. For more information, contact us at the number on the Home Page.

Compliance Services USA (C) 2021 Book One Operating Policies and Procedures Licensed for your use through 8/31/2022

NONDISCLOSURE and CONFIDENTIALITY AGREEMENT


This Nondisclosure Agreement (this "Agreement") is made effective as of 2021 (the "Effective Date"), by and between American Mortgage Services, Inc (the "Owner"), and (the "Recipient"), of The Owner is a special purpose financial services or mortgage business dealing in non public information. The purpose of this confidentiality agreement is to insure complete confidentiality as to the nature of the business. The Owner has requested that the Recipient who is a third party settlement services provider,protect the confidential material and information which may be disclosed between the Owner and the Recipient. Therefore, the parties agree as follows.

1.Confidential Information. The term "Confidential Information" means any information or material which is proprietary to the Owner, whether or not owned or developed by the Owner, which is not generally known other than by the Owner, and which the Recipient may obtain through any direct or indirect contact with the Owner.
    "Confidential Information" includes without limitation:
  • mortgage broker or customer business records and plans
  • mortgage broker or customer financial statements
  • trade secrets
  • technical information
  • products
  • pricing structure and any other proprietary or non-public information.
    "Confidential Information" does not include:
  • matters of public knowledge that result from disclosure by the Owner;
  • information rightfully received by the Recipient from a third party without a duty of confidentiality;
  • information independently developed by the Recipient;
  • information disclosed by operation of law;
  • information disclosed by the Recipient with the prior written consent of the Owner; and any other information that both parties agree in writing is not confidential.
2.Protection of Confidential Information. The Recipient understands and acknowledges that the Confidential Information has been developed or obtained by the Owner by the investment of Compliance Services USA (C) 2021 Book One Operating Policies and Procedures significant time, effort and expense, and that the Confidential Information is a valuable, special and unique asset of the Owner which provides the Owner with a significant competitive advantage, and needs to be protected from improper disclosure. In consideration for the receipt by the Recipient of the Confidential Information, the Recipient agrees as follows:
  • No Disclosure. The Recipient will hold the Confidential Information in confidence and will not disclose the Confidential Information to any person or entity without the prior written consent of the Owner.
  • No Copying Modifying. The Recipient will not copy or modify any Confidential Information without the prior written consent of the Owner.
  • Unauthorized Use. The Recipient shall promptly advise the Owner if the Owner becomes of aware of any possible unauthorized disclosure or use of the Confidential Information.
  • Application to Employees. The Recipient shall not disclose any Confidential Information to any employees of the Recipient, except those employees who are required to have the Confidential Information in order to perform their job duties in connection with the limited purposes of this Agreement. Each permitted employee to whom Confidential Information is disclosed shall sign a nondisclosure agreement substantially the same as this Agreement at the request of the Owner.

3.Unauthorized Disclosure of Information - Injunction. If it appears that the Recipient has disclosed (or has threatened to disclose) Confidential Information in violation of this Agreement, the Owner shall be entitled to an injunction to restrain the Recipient from disclosing the Confidential Information in whole or in part. The Owner shall not be prohibited by this provision from pursuing other remedies, including a claim for losses and damages.
4.Return Of Confidential Information. Upon the written request of the Owner, the Recipient shall return to the Owner all written materials containing the Confidential Information. The Recipient shall also deliver to the Owner written statements signed by the Recipient certifying that all materials have been returned within five (5) days of receipt of the request.
5.Relationship Of Parties. Neither party has an obligation under this Agreement to purchase any service or item from the other party, or commercially offer any products using or incorporating the Confidential Information. This Agreement does not create any agency, partnership, or joint venture.
6.No Warranty. The Recipient acknowledges and agrees that the Confidential Information is provided on an "AS IS" basis. THE OWNER MAKES NO WARRANTIES, EXPRESS OR IMPLIED, WITH RESPECT TO THE CONFIDENTIAL INFORMATION AND HEREBY EXPRESSLY DISCLAIMS ANY AND ALL IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. IN NO EVENT SHALL THE OWNER BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, OR Compliance Services USA (C) 2021 Book One Operating Policies and Procedures CONSEQUENTIAL DAMAGES IN CONNECTION WITH OR ARISING OUT OF THE PERFORMANCE OR USE OF ANY PORTION OF THE CONFIDENTIAL INFORMATION, The Owner does not represent or warrant that any product or business plans disclosed to the Recipient will be marketed or carried out as disclosed, or at all. Any actions taken by the Recipient in response to the disclosure of the Confidential Information shall be solely at the risk of the Recipient.
7.Limited License to Use. The Recipient shall not acquire any intellectual property rights under this Agreement except the limited right to use as set forth above. The Recipient acknowledges that, as between the Owner and the Recipient, the Confidential Information and all related copyrights and other intellectual property rights, are (and at all times will be) the property of the Owner, even if suggestions, comments, and/or ideas made by the Recipient are incorporated into the Confidential Information or related materials during the period of this Agreement.
8.Indemnity. Each party agrees to defend, indemnify, and hold harmless the other party and its officers, directors, agents, affiliates, distributors, representatives, and employees from any and all third party claims, demands, liabilities, costs and expenses, including reasonable attorneys fees, costs and expenses resulting from the indemnifying party's material breach of any duty, representation, or warranty under this Agreement
9.Attorneys Fees. In any legal action between the parties concerning this Agreement, the prevailing party shall be entitled to recover reasonable attorneys fees and costs.
10.General Provisions. This Agreement sets forth the entire understanding of the parties regarding confidentiality. Any amendments must be in writing and signed by both parties. This Agreement shall be construed under the laws of the State of Florida. This Agreement shall not be assignable by either party. Neither party may delegate its duties under this Agreement without the prior written consent of the other party. The confidentiality provisions of this Agreement shall remain in full force and effect at all times after the effective date of this Agreement. If any provision of this Agreement is held to be invalid, illegal or unenforceable, the remaining portions of this Agreement shall remain in full force and effect and construed so as to best effectuate the original intent and purpose of this Agreement.
Owner (Broker or Lender):
By:
Recipient:
By:
Compliance Services USA (C) 2021 Book One Operating Policies and Procedures

Privacy Policy

Financial Services Modernization Act of 1999
Updated May 31st, 2018

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally identifiable information' (PII) is being used online. PII, as used in US privacy law and information security,is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website. Our Privacy Officer is Shannon Robinson.

What personal information do we collect from the people that visit our blog, website or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, social security number or other details to help you with your experience.

When do we collect information?

We collect information from you when you place an order, subscribe to a newsletter, respond to a survey, fill out a form at application or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communi cation, surf the website, or use certain other site features in the following ways:

  • To personalize user's experience and to allow us to deliver the type of content and product offerings which you are most interested.
  • To allow us to better service you in responding to your customer service requests.
  • To quickly process your transactions.
  • To send periodic emails regarding your order or other products and services.
How do we protect visitor information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

Compliance Services USA (C) 2021 Book One Operating Policies and Procedures

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

Do we use 'cookies'? We do not use cookies for tracking purposes You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a . little different, so look at your browser's Help menu to learn the correct way to modify your cookies.If you disable cookies off, some features will be disabled that make your site experience more efficient and some of our services will not function properly. However, you can still place orders.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. Third party links Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites. Google Advertising Requirements Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users.

Google's advertising requirements

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adordspolicy/answer/1316548?hl=en We have not enabled Google AdSense on our site but we may do so in the future.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online. We do not specifically market to children under 13.

European Union Requirements

We do not intend to share your personal data outside the European Economic Area (EEA). We may be subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such, we may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or if we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards are available we will request your explicit consent to the specific transfer via email. You will have the right to withdraw this consent at any time.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email as soon as reasonable after discovery of the data breach. We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
  • Send information, respond to inquiries, and/or other requests or questions.
  • Process orders and to send information and updates pertaining to orders.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be accordance with CANSPAM we agree to the following:
  • NOT use false, or misleading subjects or email addresses
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can
  • Email us and we will promptly remove you from ALL correspondence.

Enterprise Wide Risk Assessment

1. Operational Controls: Description of Function: These are the agreed upon policies and procedures by which the management of the company can properly monitor its compliance with State and Federal Laws and Regulations. These policies and procedures include the following:

  • AML, OFAC, and BSA Fincen Procedure for SARS reporting
  • Red Flag Grids and Training on how to utilize
  • Privacy Policy, Clean Desk Policy, Social Media and Email Policy
  • Non-Disclosure Agreements and when to require them
  • Secure Transmission Procedures
  • Identity Theft Prevention Plan including Red Flag Grid
  • New York Only: Fair Lending Act Policy and Procedures amended to include GENDA and NY Executive Letter 296-A
  • Respa Policy non-Trid
  • TILA Respa Policy TRID
  • FTC Advertising Policy
  • Customer Complaint Policy and Procedure
  • QM, Ability to Repay, and Anti-Steering Policies
  • File Retention Policy
  • Cybersecurity Policy with Exemption Forms if applicable
  • Proforma annual and semi-annual corporate governance minutes o Sexual Harassment Concerns when applicable due to the company's number of employees.
  • Management Review and Reporting of deficiencies
  • Record Keeping

Risk Assessment: As the company has an ongoing compliance program in place, its risk assessment for Operational Controls is moderate at present.

  • The company shall complete a risk assessment analysis of every operational control above at least semi-annually. At that time, the rating can be adjusted up or down.
  • Annually, the auditor who handles the end of year financial audit will be required to address compliance with operational controls. A second risk assessment rating shall be assigned by the auditor and included in the audit notes.

10.Impact of Licensee Deficiencies on their Regulatory Risk: Any combination of one or more of the above creates regulatory risk.

Risk Assessment: At the present date, risk assessment is low.

Specific Mitigation Control: The cure for any conduct creating regulatory risk, is to promptly cure the conduct in question

  • Identify the source.
  • Retrain, and if necessary, discipline the employee.
  • Create a permanent written record about the incident and the solution.

Impact from Regulatory Changes outside the control of the Licensee: As this is a highly regulated industry, the potential for regulatory change is moderate.

Risk Assessment: At the present date, the risk is moderate.

Specific Mitigation Control:
  • Compliance Officer subscribes to regulatory update web sites and reads the updates once a month.
  • Compliance Officer takes concerns over application and implementation to outside compliance counsel as need arises.
  • Annually, outside compliance counsel reviews changes with Compliance Officer to validate compliance.