PRIVACY POLICY

Wholesale Mortgaging recognizes the importance of privacy and confidentiality. This policy applies to all of our employees, as well as our contractors, vendors, and other individuals or business associates ('Interested Parties') with whom we do business, and where such business may require access to personal or confidential information

The protection of the confidential nature of every client's personally identifiable information is of paramount importance to us; the oversight and enforcement of that protection is an integral component of our operations and informs our procedures and job descriptions. To protect that information, and in compliance with federal and state privacy laws, we have developed this Privacy Policy to make our clients and Interested Parties aware that Wholesale Mortgaging maintains confidential, personal information about its clients and their employees.

Personal Information includes any information about an individual that, when taken individually or together, makes them and their information identifiable beyond what is publicly available, such as name, address, age, gender, Social Security number, identification numbers, income, ethnicity, religion, health records, etc.

Should access to private information be required by anyone other than Interested Parties, please contact the Principal Privacy Officer ('PPO') in writing at:

WholesaleMortgaging

Attn: Principal Privacy Officer

2PlumTreeLnSomerset,NJ08873

Please include all information necessary to determine if access should be granted. Except where prohibited by law, if access is granted, you will be required to comply with this Privacy Policy and submit an attestation ofhavingreceived,readandunderstandthispolicy.No access will be given without an executed attestation by an authorized individual regardless of need, except where such access is commanded by law.

This policy applies to all of the services offered by Wholesale Mortgaging, as well as those offered by our subsidiaries or affiliated companies, if any, and their Interested Parties.

As a condition of employment or other relationship with Wholesale Mortgaging, anyone with information about a violation of this policy, or who believes that a violation of this policy may have occurred or may occur, must contact the PPO immediately.

PersonalInformationCollectioninthePerformanceofServices

Wholesale Mortgaging may collect Personal and Private Information ('PI') for the purposes of providing risk management and financial services to our clients. The services provided may include communicating with clients and participants in the financial markets, analyzing client risks, preparing policies for individuals and businesses, preparing submissions to the financial markets, processing transactions, assisting in claims, adjustments, and legal matters, etc.

We will only use PI in a reasonable manner, consistent with providing these services. Wholesale Mortgaging discloses this information only to employees and Interested Parties for the sole purpose of performing risk management and financial services on behalf of our clients, and as permitted or required by applicable law.

Wholesale Mortgaging

Information Security
Except as permitted by law, Wholesale Mortgaging does not disclose any NPI, PII, or PHI without written consent, specific to the disclosure, by the insured. All PI collected, used, and retained by Wholesale Mortgaging is secured by three layers of protection:

     premiseandphysicalsecurity

     technologicalandinfrastructuresecurity

     policiesandprocedures,includingroutineaudits

AllInterestedPartiesaresubjecttothese,asapplicablefortheperformanceoftheirresponsibilities.

EffectiveasofJanuary1,2017

1. 4.18