PROTECTING YOUR PRIVACY

We know that protecting your privacy is a very sensitive and important matter to you. Safeguarding your privacy is also a very important concern to Homestead Funding Corp. d/b/a First Niagara Mortgage. We realize that we will obtain access to confidential personal information about our customers as part of a residential mortgage loan transaction. Needless to say, protecting your privacy, by establishing policies, procedures and practices designed to prevent any unauthorized access of this confidential personal information, is a very high priority to us.

In furtherance of this goal, we have established this Privacy Policy to insure that all consumers, customers or former customers are informed regarding our privacy policy. This Privacy Policy confirms that your non-public personal information is protected, and will only be able to be accessed by the employees who need to know the information in order to provide mortgage products or services to you, or by third parties who need this information so that they can provide related services necessary for us to process, service administer or close your mortgage loan.

A “customer relationship”, for purposes of this Privacy Policy, could arise in a number of ways. First, a customer is anyone whose mortgage loan is owned and serviced by us. A customer is also anyone who has applied for or is in process of applying for a mortgage loan, through us, when the anticipated loan is a bankered product to be closed in our name. Finally, a customer is anyone who has applied for or is in the process of applying for a brokered mortgage loan through us, in which case we will seek to obtain a mortgage loan for our customer through another bank offering mortgage products with which we have a business relationship.

No matter how the customer relationship is created, we value the privilege of serving you. We appreciate the trust you have placed in us, by asking us to help you obtain a mortgage loan. We hope your experience with us is, in every way, satisfactory. Through the adoption of this Privacy Policy, and our strict adherence to it, we hope to further enhance your trust in us.

WHAT INFORMATION HOMESTEAD COLLECTS

We collect nonpublic personal information about consumers and customers from the following sources:

• Information we receive from you during conversations with our employees, on applications, or other forms you send to us, or your contact with our website
• Information we receive from a consumer reporting agency regarding your credit
• Information we receive pursuant to your authorization from your present or former employers, banking institutions, mortgage servicers, and investment & stock brokerage firms
• Information we receive from banks with whom we do business as a mortgage broker
• Information received from public or governmental sources

INFORMATION WE DISCLOSE ABOUT YOU

We do not share any nonpublic personal information about you with anyone except:

• Those third parties who perform marketing services on our behalf, or financial institutions with whom we have joint marketing agreements that provide for the confidentiality and security of your non public personal information.
• As permitted by law.

INFORMATION WE DISCLOSE ABOUT CONSUMERS AND FORMER CUSTOMERS

We do not disclose any nonpublic personal information about consumers or former customers to anyone, except:

• Those third parties who perform marketing services on our behalf, or financial institutions with whom we have joint marketing agreements that provide for the confidentiality and security of your non public personal information.
• As permitted by law.

THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR NONPUBLIC PERSONAL INFORMATION

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide mortgage products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information from unauthorized disclosure.

DEFINITIONS

As used herein, the following terms are intended to have the meanings expressed below:

We, our, us, and Homestead, as used in this Privacy Policy, are intended to mean Homestead Funding Corp. d/b/a First Niagara Mortgage.

When we use the words “you”, “your”, or “customer”, we mean all of our customers, such as:

• All of our borrowers, or prospective borrowers, for a mortgage loan obtained through us acting as a mortgage banker; or
• All of our borrowers and prospective borrowers for a mortgage loan arranged through us with a different lender, where we are acting as the mortgage broker; or
• All of the borrowers of mortgages we own and service or arrange to have sub-serviced in our name.

A consumer, for purposes of this Privacy Policy, is anyone who contacts us seeking a mortgage loan that provides us with any personal information to obtain a mortgage, even if the loan application is not ultimately consummated with a mortgage loan transaction.

Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you that is confidential in nature. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.

An affiliated company is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control. First Niagara Bank, for instance, is an affiliate of ours.

A nonaffiliated third party is a company that is not an affiliate of ours.