FirstMerit Corporation and its subsidiaries are committed to providing non-discriminatory lending services to all loan applicants and potential loan applicants. It's about fairness, and FirstMerit does not tolerate discriminatory lending practices in any form, as they are socially destructive, morally offensive, and unlawful.

For more than 160 years FirstMerit Bank has assisted its customers and communities with comprehensive banking services. FirstMerit's success begins with a philosophy of trust, fairness, and maintaining close personal relationships with its customers. We want every customer to know and understand we are committed to the guidelines and laws of the Equal Credit Opportunity Act, the Community Reinvestment Act, the Home Mortgage Disclosure Act, the Fair Housing Act, the Americans with Disabilities Act and applicable state non-discrimination laws, such as the Ohio Fair Housing Law. At FirstMerit every applicant receives fair and equal treatment throughout the application and approval process.

We want our communities to know we are committed to providing professional, ethical and non-discriminatory products and services. We locate our branches in areas that are accessible to individuals from all parts of our market areas, and we continually analyze our product lines to ensure we are meeting the changing needs of all our distinct communities. We price our products and services in a non-discriminatory manner. Our advertising promotes our Corporate name and our products to all segments of our market.

Fair Lending practices are consistent with safe and sound banking operations. Therefore, our lending policies and procedures are designed to promote equality and fairness for all credit applicants. An applicant's race, color, religion, age, sex, national origin, familial status, marital status, handicap, ancestry, their receipt of public-assistance income, their previous good-faith exercise of rights under the Consumer Credit Protection Act, and the racial composition of the neighborhood in which their housing accommodations are located will not be considered during any part of the credit-granting or loan-servicing process. In addition, any similar information we may receive regarding any person associated with the credit applicant, or any present or prospective occupants of the property to be financed, will also not be considered in our decision-making process.

Every person who considers applying for a loan from a FirstMerit affiliate will be encouraged to do so. We present each applicant with all available options and provide the same level of assistance to all applicants within each type of credit. Credit terms and conditions are offered without regard to any of the prohibited bases, and underwriting standards are applied uniformly and objectively. All credit decisions are made solely on the basis of the applicant's creditworthiness. We respond to all credit inquiries within the time frames specified by the Equal Credit Opportunity Act. FirstMerit furnishes accurate and appropriate credit information to credit reporting agencies, and service all loans under our control in a non-discriminatory manner.

All of FirstMerit Corporation's employees are responsible for promoting themselves and the Corporation in a non-discriminatory manner. To assist in this objective, "diversity training" is available to all employees. In addition, lending-related employees and managers are required to attend regular training on Fair Lending issues. Senior management is updated periodically on internal non-discrimination activities and informed about fair lending actions in the marketplace. Each FirstMerit employee must understand the requirements of the Fair Lending laws as they apply to their job and actions.

Internal policies and procedures, as well as past and present loan applications and loan documents, are reviewed regularly to ensure applicants are not being treated differently. This reviews also ensures that the effects of the FirstMerit's lending practices, procedures and policies are not resulting in different outcomes on a prohibited basis. To the extent possible, statistical analysis and modern technology is used in this review.

If loan decisions are made, in whole or in part, with an artificial intelligence system, the predictive ability of this system will be periodically revalidated as required by the Equal Credit Opportunity Act.

Firstmerit's internal and external hiring and promotion practices, the diversity of our current staff, and our internal compensation packages are periodically reviewed to ensure we are employing, promoting, and compensating staff in a manner consistent with the goals of the Fair Lending laws.

FirstMerit joins other financial instructions to ensure Fair Lending initiatives are directly linked to the organization's comprehensive strategic plan, and are intended to strengthen both the Corporation and society as a whole.