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Federal laws and regulations require us to disclose how we use information that we collect when you apply for a loan.  The following policy serve as a standard for all Sterling Mortgage & Investment Co. (a/k/a First Finance) and Express Lenders: Lenders to America, Inc. employees for collection, use, retention and security of  “nonpublic personal information.” Sterling Mortgage & Investment Co. (a/k/a First Finance) and Express Lenders: Lenders to America, Inc. are affiliated corporations.

What Information We Collect:

We collect “nonpublic personal information” about you from the following sources:

• Information we received from you on applications or other forms;
• Information about your transactions with our affiliates, others; or us
• Information we receive from consumer reporting agencies (credit bureaus) and other third parties; and
• Information we receive from you when you fill out an electronic form at our Internet web site.

“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you.  For example, nonpublic personal information includes information regarding your account balances, rent or mortgage payment history, and income that we collect when we process your request for a mortgage loan.

What Information We Disclose:

We are permitted under law to disclose nonpublic personal information about you to other third parties in certain circumstances.  We may disclose all of the information that we collect about you, including the following kinds of “nonpublic personal information:”

Who We Disclose Information To:

We may disclose all of the nonpublic personal information that we collect about you (as described above) to the following types of third parties:

• Service Providers, such as appraisers, title insurance agencies, title insurance companies, surveyors, credit bureaus, document preparation companies, accountants, marketing companies, auditors, and attorneys.
• Financial institutions and affiliates with whom we have joint marketing agreements and arrangements.
• Lenders, affiliates and investors who will process, fund, service or purchase your loan.
• Government agencies and private mortgage insurance companies that insure or guaranty your loan.
• Non-financial companies, such as home improvement contractors.

We are permitted under law to share information about our experience or transactions with you or your loan (such as your loan amount and your payment history with us) with companies related to us by common control or ownership (“affiliates”).  We also may share additional information about you or your account (such as information we received from you in applications and information from credit reporting agencies) with our affiliates.  You may direct us not to disclose to our affiliates information that does not relate solely to our or our affiliates - experiences or transactions with you or your account (such as the application information and credit bureau information) by writing us at 31333 West Thirteen Mile Road, Farmington Hills, Michigan 48334.

We may also disclose nonpublic personal information about you to other non-affiliated third parties as permitted by law.  However, we do not disclose information about you to marketers or other persons who are not working to provide credit or other services to you.

Our Security Procedures:

We restrict access to nonpublic personal information about you to those employees, settlement service providers, lenders and investors who need to know that information to provide a mortgage loan to you. Employees who violate these standards will be subject to disciplinary measures.  Your personal information is maintained in our offices, which are secured during non-business hours.  We maintain physical, electronic and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information.

If you decide not to become our customer, or you are no longer our customer, we will continue to adhere to the privacy policies and practices described in this Disclosure.