GreenPoint Mortgage, Inc. ("GPM") is a wholly-owned subsidiary of Capital One, N.A.. GPM has adopted a Fair Lending Policy Statement (the "Policy"), the purpose of which is to prevent unlawful discriminatory practices in relation to its lending activities and to ensure compliance with all applicable federal and state laws, including but not limited to the federal Equal Credit Opportunity Act ("ECOA"), the Federal Reserve Board's Regulation B, the Fair Housing Act, and New York Executive Law §296-a.

1. General Policy Statement
   GPM and all of its subsidiaries will not discriminate with respect to any aspect of a credit decision on the basis of race, color, religion, national origin, sex, marital or familial status, disability, age (provided that an applicant has the capacity to enter into a binding contract), receipt of income from any public assistance program, sexual orientation, military status, or the good faith exercise of any rights under the federal Consumer Credit Protection Act.

   GPM is fully committed to the principle that all credit decisions should be made without regard to race or any other basis prohibited by law. GPM recognizes that affirmative steps must be taken to ensure that this Policy is applied consistently and continuously through all aspects of its credit operations, including product design, marketing and advertising, and the application and underwriting processes. GPM will regularly monitor its residential mortgage lending activity to make certain they comply with this Policy. Where our review suggests a deviation from the Policy may have occurred, GPM will act expeditiously to investigate, and if necessary, institute corrective measures. GPM will implement this Policy while maintaining prudent credit discipline and helping achieve an acceptable return for Capital One shareholders.

2. Advertising
   GPM will not engage in advertising practices that would discourage on a prohibited basis the making or pursuing of an application for credit and will comply with the requirements of applicable law relating to the nondiscriminatory advertising of credit. Where required, all advertising, press releases, and marketing materials for its mortgage lending activities shall include a facsimile of the equal housing lender logotype and legend (see below).
3. Applications and Information Gathering Applications and Information Gathering Oral or written statements that tend to discourage potential applicants on a basis prohibited by law will not be employed with regard to oral or written inquiries and applications. The application process will be neutral in nature and of a type applicable to every applicant desiring the same kind and amount of credit. Lending officers, loan underwriters, and other GPM employees involved in the mortgage and loan origination process may not ask prohibited questions regarding: a spouse or former spouse; marital status; familial status; military status; sex; alimony, child support, or separate maintenance income; child bearing; national origin; race; color; religion; or sexual orientation
4. Application Processing and Evaluation; Mortgage Application Second Review Process
   GPM will not use any information it obtains to discriminate on a prohibited basis. No residential mortgage application submitted to GPM will be declined unless the decision to decline is supported by an underwriting supervisor or an operations manager.
5. Credit Extension
   GPM will not discriminate on a prohibited basis in the extension or denial of credit.

   Signature Requirement

   1. GPM will not require the signature of a person other than the applicant (or joint applicant) on any credit instrument if the applicant qualifies for the amount and terms of the credit requested under GPM’S existing standards of creditworthiness for the amount and terms of the credit requested.
   2. To the extent permitted by applicable law, GPM may require the signature of any individual or entity on instruments that it concludes are necessary to obtain a valid security interest on property offered by an applicant in connection with a credit obligation.
6. Notification
   GPM will provide notices of action taken on loan applications in accordance with the provisions of the ECOA and Federal Reserve Board Regulation B.
7. Record Retention
   GPM will maintain the following information, as required by law:

   A.	Application form.
   B.	Written or recorded information used in evaluating an application (including any notes or memoranda made by a lending officer) and not returned to the applicant at the applicant's request.
   C.	Written or recorded information regarding any action taken concerning a new or existing extension of credit, including a copy of any statement of specific reasons for adverse action.
   D.	Information obtained for purposes of government monitoring.
   E.	Any claim or accusation of alleged discrimination or other violation of law submitted by an applicant or existing customer.

   Unless a shorter retention period is permitted by applicable law, the information listed above will be maintained for a minimum of 25 months after the date on which GPM notifies an applicant of action taken on an application or of incompleteness of an application.

8. Third Parties
   All contracts establishing a relationship between GPM and a third party correspondent, mortgage broker or mortgage banker shall contain a provision under which the third party acknowledges and agrees to abide by applicable fair lending laws.
9. Government Monitoring Information
   As required by applicable law, GPM will request and maintain information from loan applicants on race, ethnicity, and sex, to allow the government to monitor compliance with nondiscrimination laws.
10. Fair Lending Training
    GPM personnel involved in residential mortgage lending will receive appropriate fair lending training.