First Direct Lending, LLC is committed to ensuring your privacy. We strive to protect the confidentiality of all information provided to us. First Direct Lending, LLC may track the way visitors use the site, however, that information is used only as generic system information, and is not used at an individual level. We do not sell individual user information, profile information or generic system information to third parties.
If you apply for a loan, we may collect nonpublic personal information about you from the following sources:
- Information we receive from you on applications and other forms;
- Information about your transactions with us, or others; and
- Information we receive from a consumer reporting agency.
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products and services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
If you have a question or would like more information contact the Compliance Department at 949.535.1998, ext. 1256.
Our web site may use “cookies” to measure site activity and to customize information to fit your preferences. Cookies enable the site to remember who you are. We do not record personal or sensitive information in our cookies. If you wish not to accept cookies you can configure your browser to reject all cookies, or notify you when a cookie is set.
Definition of Cookies
A “cookie” is a small piece of information sent by a web server to a web browser enabling the browser to remember specific bits of information. The information stored within a cookie can be read only by the web server that originally sent the cookie.
Types of Cookies
The two types of cookies are session cookies and persistent cookies. The key difference between session cookies and persistent cookies is the time of expiration. Session cookies expire at the end of the session and Persistent cookies do not expire at the end of the session.
We take your online privacy serious and you can be assured that any information provided by you will be kept confidential.
Acceptance of Terms
Products and Services
First Direct Lending, LLC generally offers first-lien residential mortgages via government and conventional channels. Not all products and services described are available in all states where First Direct Lending, LLC is licensed.
Fair Lending Policy
First Direct Lending, LLC does not discriminate against any applicant or discourage anyone on a prohibited basis from submitting an application. To assure that our employees have a clear and unequivocal statement of our commitment to a nondiscriminatory method of doing business, we have adopted the following fair lending policy. Employees must be thoroughly familiar with this policy and follow it.
- First Direct Lending, LLC (“First Direct”) its directors, executives and managers recognize the importance and significance of an articulated fair lending policy. The foregoing policy statement is considered to be a core element of the company’s operational business plan. As appropriate and in accordance with the company’s business model, the anti-predatory policy and procedures described herein shall apply to all residential mortgage transactions and represent the full scope of products, property types and geographic locations. The foregoing policies and procedures shall be distributed to all employees on an inter-departmental level. The anti-predatory lending policy shall be strictly enforced on all service delivery channels, including but not limited to: in-person applications, telephone applications, web-based applications and mail applications.
- First Direct Lending has instituted corporate-wide technology systems and workflow processes to ensure compliance to the Dodd-Frank Wall Street Reform and Consumer Protection Act, state-specific consumer disclosures and federal fair lending laws, including: the Equal Credit Opportunity Act (ECOA), Fair Housing Act (FHAct), Fair Credit Reporting Act (FCRA), Home Owners Equity Protection Act (HOEPA), Flood Disclosure Act, Home Mortgage Disclosure Act (HMDA), Real Estate Settlement Procedures Act (RESPA), Truth in Lending Act (TILA), Mortgage Disclosure Improvement Act (MDIA), Appraiser Independence and the Fair and Accurate Transactions Act (FACTA), including the most recent amendment to FACTA regarding Red Flags to identify, detect and mitigate identity theft.
- The fair lending program shall comply with the most recently published rules of the Consumer Financial Protection Bureau (CFPB) including, but not limited to, self-examination steps following the procedures outlined in the “Interagency Guidelines for Self-assessment.”
- Various state laws also govern fair lending, including New York Executive Law § 296-a, which makes it an unlawful discriminatory practice for any creditor to discriminate on the basis of race, creed, color, national origin, age, sex, marital status, disability, familial status, sexual orientation, or military status; to discriminate on a prohibited basis in the granting, withholding, extending or renewing, or in fixing the rates, terms or conditions of any form of credit; to use any form of application for credit or use or make any record or inquiry which expresses, directly or indirectly, any limitation, specification, or discrimination as to a prohibited bases; to make any inquiry of an applicant concerning his or her capacity to reproduce, or his or her use or advocacy of any form of birth control or family planning; to refuse to consider sources of an applicant’s income or to subject an applicant’s income to discounting, in whole or in part, because of a prohibited basis or childbearing potential; or to discriminate against a married person because such person neither uses nor is known by the surname of his or her spouse.
- We make sure that our scoring system is empirically derived and statistically sound and uses no prohibited basis other than age as a predictive factor.
- We train our loan personnel in the principles of fair processing and underwriting.
- Our Quality Control Department regularly reviews both our loan underwriting standards and the business practices by which we implement them to determine whether they ensure equal lending opportunity and reports to management.
- We periodically review our loan portfolio and applications to make sure that we are serving the community adequately and on a nondiscriminatory basis in light of the community’s demographic characteristics and credit demands.
- We conspicuously display the poster in a public area of each of our facilities stating that we are ascribing to the Equal Housing Act. Additionally, on all forms of advertisements, regardless of media, we include the Equal Housing Opportunity logo and/or the Equal Housing Opportunity slogan.
Intellectual Property, Logo Licensing and Links
Copyright 2015, First Direct Lending, LLC. All rights reserved. Materials and intellectual property found on websites owned by First Direct Lending, LLC are protected by copyright and other intellectual property laws and treaties in the United States and worldwide. Trademarks, service marks and logos used on websites owned by First Direct Lending, LLC, registered and unregistered, are subject to United States trademark law. You may not copy, reproduce, modify, store, transmit, or distribute any part of intellectual property, trademarks, service marks or logos found on websites owned by First Direct Lending, LLC without specific written consent from First Direct Lending, LLC.
Content contained in websites owned by First Direct Lending, LLC should not be construed to be legal or financial advice. Users are responsible for obtaining their own competent legal and financial advice from qualified providers at their own expense.
Mortgage calculators/calculations which may be provided within websites owned by First Direct Lending, LLC are provided solely for estimation and are hypothetical. You are responsible for the accuracy of any estimates and should not rely solely on these calculators. Seek advice from qualified providers before you make any financial decisions.
By using, accessing or attempting to access websites owned by First Direct Lending, LLC that require the use of Passwords or any other method of authentication or any combination of authentication methods (these are defined as “secure websites”), you are certifying you are the person legally associated with the passwords or method(s) of authentication being used. Unauthorized access, attempted access, use or attempted use of secure websites owned by First Direct Lending, LLC is prohibited and may violate federal and/or state law. Unauthorized access, attempted access, use, or attempted use of secure websites owned by First Direct Lending, LLC may be reported to law enforcement.
Links to Other Sites – Limitation of Liability
First Direct Lending, LLC may provide links to or from other web sites that First Direct Lending, LLC does not have control over. You agree that First Direct Lending, LLC is not responsible for any liability resulting from the access or use of sites not owned by First Direct Lending, LLC. You also agree that First Direct Lending, LLC is not responsible for any content, advertising, or products available through these websites. Further, you agree that First Direct Lending, LLC shall not be responsible or liable, directly or indirectly, for any damage or loss caused, or alleged to be caused by or in connection with the use of websites First Direct Lending, LLC owns.
Monitoring and Blocking
LIMITATION OF LIABILITY
YOU AGREE THAT YOUR ACCESS TO, AND USE OF, WEBSITES OWNED BY FIRST DIRECT LENDING, LLC AND THE CONTENT THEREOF IS AT YOUR RISK. YOU AGREE, THAT UNDER NO CIRCUMSTANCES SHALL FIRST DIRECT LENDING, LLC BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE OR EXEMPLARY DAMAGES ARISING FROM VIRUSES, WORMS, TROJAN HORSES OR OTHER CODE THAT HAS CONTAMINATING OR DESTRUCTIVE PROPERTIES OR YOUR REFERENCING, USING, ACCESSING, INABILITY TO USE OR ACCESS OR LINKING TO OR FROM THE WEBSITES OF FIRST DIRECT LENDING LLC OR ANY ERRORS OR OMISSIONS IN THE CONTENT THEREOF. There are some jurisdictions that do not allow for the exclusion of certain warranties or the limitation or exclusion of liability for consequential or incidental damages. Based on this conclusion, the liability of First Direct Lending, LLC is limited to the greatest extent permitted by law.
Governing Law; Severability
If you have concerns about the misuse of your personal data or would like to correct any of the personal information you have submitted to us, please contact us at firstname.lastname@example.org or by phone at 949.535.1998 ext. 1256.
Website Safeguard Policies and Procedures
At First Direct Lending, LLC we take information security seriously. Although there are many components, systems and vendors that comprise the website solution, First Direct Lending, LLC is responsible for the security of customer information. Any customer specific information collected from the customers are to be protected using industry standard security protocol.
Risks to Consumer Data and Information Systems
In certain instances consumers will provide information to First Direct Lending, LLC via its website. No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure, however, the Company takes extensive measures to protect its customer’s as outlined below.
Security Measures and Provider Due Diligence
First Direct Lending, LLC performs appropriate due diligence in selecting service providers to ensure that they meet Company needs and expectations and that they have adequate security controls to safeguard our customer information.
First Direct Lending, LLC uses hosting services at Go Daddy. They are a highly secure tier 1 provider. Go Daddy is SOC, SSAE 16, and SAS 70 compliant. These are very stringent security requirements and provides the level of security confidence required. Go Daddy compliance will be reviewed annually to ensure their SOC security certification has not been revoked. As of June 15, 2011, SAS 70 reports are no longer valid. The SAS 70 was replaced by the SSAE 16, SOC (Service Organization Control) report. Created and maintained by the American Institute of Certified Public Accountants (AICPA), the SSAE 16 SOC report verifies, with an independent party, that our operations meet professional standards. Vendors are required to be a tier 1 providers with SOX compliant security measures, redundancy and disaster recovery in place. To ensure the highest level of security protection, exact security equipment and process is not released by Go Daddy. This policy from Go Daddy is to firewall knowledge of the internal architecture to potential hackers. Go Daddy’s certification by independent 3rd party auditor ensures there infrastructure and process meets or exceeds certification requirements.
Go Daddy has redundant firewalls, malware scanning and DDoS protection. The core updates with the latest security patches are automatically applied to FDL’s website. The Go Daddy security team is on the job 24/7, monitoring our site for suspicious activity and protecting it against brute force and DDoS attacks.
All consumer data is encrypted from the browser to the server. This traffic uses SSL Certificates (Secure Socket Layer) to validate First Direct Lending, LLC website’s identity, and encrypt the information visitors send to, or receive from, our site. This keeps thieves from spying on any exchange between First Direct Lending, LLC and our customers. An SSL Cert protects our customers’ sensitive information such as their name, address, etc. by encrypting the data during transmission from their computer to the GoDaddy hosted web server. SSL is the standard for web security. First Direct Lending, LLC site’s SSL certificate enables the browser and Web server to build a secure, encrypted connection. The SSL “handshake” process, which establishes the secure session, takes place discreetly behind the scene without interrupting the consumer’s web experience. A “padlock” icon in the browser’s status bar and the “https://” prefix in the URL are the only visible indications of a secure session in progress. All SSL-protected sites display the https:// prefix in the URL address bar.
First Direct Lending, LLC’s current Safeguard Policy statement includes requirements for strict adherence for user access controls, such as secure password policy and limited badge access to server room. Data encryption is protected by Transport Layer Security (TLS) to include Secure Sockets Layer (SSL) communications. Software patch updates are handled as needed. Server security is addressed in THREE separate locations via encrypted SSL communications. Penetration testing may be handled by a third party vendor/consultant on a reasonable basis. Malicious code prevention and intrusion detection systems are part of the services provided by Microsoft, Ellie Mae, and Velocify.