Consumer Complaint Policy

Revision Date: 3/8/2024

1. Overview

Consumer complaints provide insight into problems that consumers are experiencing, help brokers and lenders identify inappropriate practices, provide an opportunity to correct issues before they become major problems, and enable Access Reverse Mortgage to provide better outcomes for consumers. Consumer complaints can also affect Access Reverse Mortgage's reputation, result in lost business, and cause regulatory scrutiny. A strong compliance management program includes processes and procedures for addressing consumer complaints, including completing prompt and thorough investigations and responses, and monitoring complaints to identify risks. For these reasons, Access Reverse Mortgage takes consumer complaints very seriously and seeks to respond in a helpful and timely manner.

2. Definitions

The following definitions apply to this Policy:

• Complaint: means an oral or written expression of dissatisfaction. It can also be an allegation, by or on behalf of an individual or a group of individuals, that a particular product, act or practice, including advertising, is unfair, deceptive, abusive, discriminatory, or otherwise in violation of laws or regulations.
• Qualified Written Request: means, as defined by the Real Estate Settlement Procedures Act (RESPA), any written correspondence, other than notice on a payment coupon or other payment medium supplied by the servicer, that includes, or otherwise enables the servicer to identify, the name and account of the borrower and includes a statement of the reasons for the belief of the borrower that the account is in error or provides sufficient detail to the servicer regarding other information sought by the borrower.

3. Policy Statement

Access Reverse Mortgage is committed to handling each complaint in a professional, expeditious manner and has established a formal consumer complaint management program to record, investigate, monitor, and track consumer complaints. Access Reverse Mortgage implements this Complaint Management Policy to provide guidance on the manner in which Access Reverse Mortgage receives and handles complaints received and to assist Access Reverse Mortgage's employees in resolving complaints in an efficient, effective and professional manner.

4. Roles and Responsibilities

Access Reverse Mortgage is committed to handling each complaint in a professional, timely manner and have established the following roles and responsibilities:

• Oversight by The Board of Directors and Executive Management: The responsibility to approve and exercise general oversight of this Policy lies with The Board of Directors and Executive Management. The responsibility to monitor and respond to complaints has been delegated by The Board of Directors and Executive Management to the Compliance Officer Ruslan Barbashin.

B. Compliance Officer Duties

The Compliance Officer is responsible for:

• tracking and monitoring consumer complaints;
• ensuring that specific complaint procedures required by regulation are followed;
• drafting, or assisting employees in drafting, responses to consumers and/or regulators;
• evaluating evolving trends to ensure appropriate action is taken to correct issues or behavior;
• informing The Board of Directors and Executive Management about complaints and trends on a regular basis; and
• ensuring that all employees are trained to recognize complaints and follow appropriate procedures.

5. Complaint Handling Procedures

Access Reverse Mortgage will provide convenient means for consumers to submit complaints. All communications of Consumer’s submitting a complaint directly to Access Reverse Mortgage will be acknowledged in a timely manner. Upon receipt of a consumer complaint the following steps should be taken:

• A. Receipt of Complaint: Employees must immediately notify their manager regarding any consumer complaint, whether received verbally or in writing. The manager shall escalate the complaint to the Compliance Officer and shall work together to resolve the complaint. The Compliance Officer must be notified of all complaints and all complaints will be logged. Complaints received directly by NextEra Finance must be resolved within thirty business days of receipt. Any complaints requiring additional time, a single fifteen-day extension is allowed, but the consumer must be notified of the extension and the reason for the delay.
• B. Investigation and Response to Complaint: Upon receiving the complaint, Compliance Officer or designee will forward a response to the consumer and, if appropriate, the relevant government or state regulatory department acknowledging receipt of the complaint and that a formal response will be forthcoming; thoroughly review and investigate the complaint; maintain complete documentation concerning the complaint and the results of investigations; send a response to the consumer when the investigation is complete and, if appropriate, to the relevant government or state regulatory department, revealing the results of its investigation and, when necessary, any corrective action taken; ensure all responses are provided timely and within the relevant government or state regulatory timeframe.
• C. Corrective Action and Reporting: The Compliance Officer or designee will also work with relevant departments to ensure appropriate corrective action is taken to address any issues; track and evaluate evolving trends to ensure appropriate action is taken to correct issues or behavior; inform The Board of Directors and Executive Management about complaints and trends on a regular basis.
• D. Fair Lending Complaints: For complaints alleging discrimination or fair lending concerns, the complaint should be escalated to the Compliance Officer and managed in accordance with the complaint handling procedures. If any discrimination is discovered, Access Reverse Mortgage will determine the cause and take appropriate corrective action. This action may include but is not limited to, the following: Offering to extend credit to the applicant, if they were improperly denied or whose applications may have been inappropriately processed; Correcting any institutional policies or procedures that may have contributed to the discrimination; Identifying, and then training and/or disciplining, the employees involved; Improving oversight systems to ensure that there is no recurrence of discrimination.

6. Mortgage Servicing Errors – Qualified Written Requests

RESPA and its implementing Regulation X have specific requirements concerning Access Reverse Mortgage's duty to respond to borrower inquiries about residential mortgage loans. Access Reverse Mortgage is a mortgage broker and does not fund or service loans, therefore Qualified Written Requests and Periodic Billing Errors are not applicable to Access Reverse Mortgage's business and are addressed directly by the actual creditor and/or servicer of the loan, as applicable In the event Access Reverse Mortgage retains servicing on a loan, Access Reverse Mortgage, or its sub-servicer, will comply with the below requirements for Qualified Written Requests (QWR).

A QWR is a written correspondence sent by a consumer (or someone working on behalf of a consumer) to the consumer’s mortgage servicer. The purpose of a QWR is to dispute an error relating to the servicing of the mortgage loan or to request information about the servicing of the mortgage loan. The regulation requires Access Reverse Mortgage, or its sub-servicer, to responds to qualified written requests from borrowers about the servicing of their residential mortgage loans within the time limits prescribed by RESPA.

Specifically, Access Reverse Mortgage, or its sub-servicer, must acknowledge receipt of the response, in writing, no later than five business days (Mondays – Fridays excluding legal public holidays, Saturdays and Sundays). Additionally, RESPA requires that Access Reverse Mortgage, or its sub-servicer, must within 30 business days: make appropriate corrections in the account of the borrower, including the crediting of any late charges or penalties, and provide to the borrower a written notification of such correction; or conduct an investigation and provide the borrower with a written explanation or clarification that includes a statement of the reasons Access Reverse Mortgage, or its sub-servicer, believes the account is correct and the contact information of an employee or office that can provide assistance to the borrower.

7. Periodic Billing Errors

Regulation Z has specific requirements for handling consumer complaints regarding billing errors on periodic billing statements and also provides specific procedures for consumers to follow in questioning creditors about items that appear on those statements. Access Reverse Mortgage is a mortgage broker and does not fund or service loans, therefore Periodic Billing Errors are not applicable to Access Reverse Mortgage's business and are addressed directly by the actual creditor and/or servicer of the loan, as applicable. In the event Access Reverse Mortgage retains servicing on a loan, Access Reverse Mortgage, or its sub-servicer, will comply with the below requirements.

Regulation Z defines billing errors to include the following items: Posting a credit that was not made by the consumer; Extension of credit that is not identified in the periodic statement; Billing for property or services not accepted by the consumer or not delivered to the consumer as agreed; Institution’s failure to properly credit a payment or other credit issued to the consumer’s account; Computational or accounting error made by the institution; Consumer’s request for additional clarification on an item appearing on his or her periodic statement, including documentary evidence; and Institution’s failure to mail or deliver a periodic statement to the consumer’s last known address if that address was received by the institution, in writing, at least 20 days before the end of the billing cycle.

The regulation requires Access Reverse Mortgage, or its sub-servicer, to respond to notifications of billing errors from borrowers within the time limits prescribed by Regulation Z. Specifically, Access Reverse Mortgage, or its sub-servicer, must acknowledge receipt of the billing error notice, in writing, no later than 30 days of receipt of the notice and must resolve the error within 90 days or less, or within two billing cycles of receiving the notice from the borrower. Two billing cycles means two full cycles after the end of the billing cycle in which notification from the borrower was received. For example, if the notification is received in mid-June, the dispute must be resolved by the end of August.

In instances where a billing error notice is resolved within 30 days or the consumer indicates (orally or in writing) that he or she is withdrawing the billing notice error, a written acknowledgement of receipt of the billing error notice is not required.



8. Training

Access Reverse Mortgage shall ensure employees are trained to identify complaints and to follow appropriate procedures for escalating, investigating, and responding to complaints timely. It is important that employees are vigilant in the complaint process to help consumers have a better outcome, reduce regulatory scrutiny, and protect Access Reverse Mortgage's reputation and business.