Purpose

It is TIAA Bank’s policy to treat you with professionalism, courtesy and fairness. Our employees strive to offer assistance, encouragement and service in a fair, equitable and consistent manner. The success of the Policy is the responsibility of the entire organization. This Policy applies across all aspects of the lending operations, including advertising and marketing, loan origination, processing, underwriting, servicing, collection, and loss mitigation activities.

TIAA Bank’s commitment to fair and responsible lending principles is demonstrated throughout the Bank’s structure and organization, in employee accountability, through various monitoring and auditing programs, and in education and training programs it offers. TIAA Bank’s Executive Management is responsible for establishing policies to ensure that operations and business practices reflect our strong commitment to fair and responsible lending, and that all employees are aware of that commitment.

Policy statement

TIAA Bank has adopted a Fair and Responsible Practices Policy (the “Policy”) to promote compliance with all applicable state and federal laws ensuring fair lending and equal access to credit, including but not limited to the federal Equal Credit Opportunity Act (“ECOA”), the Federal Reserve Board’s Regulation B (which implements ECOA) and the Fair Housing Act. The Policy is also adopted to prevent unlawful discriminatory practices in relation to its lending activities and to prevent unfair, deceptive and abusive practices.

TIAA Bank will not discriminate with respect to any aspect of a credit decision on the basis of race, color, religion, national origin, sex, marital 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, the good faith exercise of any rights under the federal Consumer Credit Protection Act. TIAA Bank is also fully committed to the principle that all decisions related to the granting or servicing of credit should be made with consideration of safe and sound business practices. TIAA Bank takes appropriate steps to ensure that this Policy is applied consistently and continuously through all aspects of its credit operations, including product design, marketing and advertising, loan application, underwriting, pricing collection, servicing, and loss mitigation activities.

If you believe that you have been subject to discrimination, you may send your complaint to one or all of the following addresses:

Office of the Comptroller of Currency (OCC)

OCC Customer Assistance Group 1301 McKinney Street, Suite 3450 Houston, TX 77010-9050

Assistant Secretary for Fair Housing and Equal Opportunity

Department of Housing and Urban Development (HUD) Washington, DC 20410 For processing under the Federal Fair Housing Act

Consumer Financial Protection Bureau (CFPB)

1500 Pennsylvania Avenue NW Washington, DC 20220

TIAA Bank

Homeowners Assistance Review Team P.O. Box 2167 Jacksonville, FL 32232