Origin Funding Code of Conduct

At Origin Funding (OF) we are committed to maintaining the highest standards of professionalism, integrity, and compliance with all applicable laws and regulations. This Code of Conduct outlines the responsibilities of our agents and staff to ensure ethical practices in all of our interactions with clients.

1. Telemarketing Calls (TCPA Compliance)

We take compliance with the Telephone Consumer Protection Act (TCPA) seriously. When conducting telemarketing calls:

• Legal Calling Hours: Agents may only dial numbers within the hours legally permitted by the TCPA, which are between 8 a.m. and 9 p.m. local time for the recipient.
• Do Not Call Requests: If a recipient requests not to receive any more calls from OF, they are immediately added to our Do Not Call (DNC) list in our system. This ensures they will not receive any further communication from our team.
• Respecting DNC Lists: We adhere to all state and federal DNC lists and ensure that our agents are trained to respect and implement these policies promptly.

2. Email Marketing (CAN-SPAM Compliance)

When engaging in email marketing, OF ensures full compliance with the CAN-SPAM Act. We follow these practices:

• Opt-Out Mechanism: Each marketing email we send includes a clear and easy-to-use mechanism for recipients to opt-out of future communications. Requests to unsubscribe are honored promptly.
• Accurate Subject Lines and Sender Information: We ensure that our email marketing is transparent. Subject lines accurately reflect the content of the message, and our ‘From’ address clearly identifies Origin Funding as the sender.
• No Misleading Information: We do not use deceptive information or messaging in our emails.

3. Fair Lending Practices

Origin Funding is committed to providing equal lending opportunities for all clients. We strictly adhere to Fair Lending laws to ensure:

• No Discrimination: Agents are prohibited from discriminating against clients based on race, color, religion, national origin, sex, marital status, age, or income derived from public assistance programs. All clients are treated fairly and equitably in every aspect of the lending process.
• Ethical Practices: Our agents undergo regular training to ensure they understand and comply with Fair Lending laws and ethical standards.

4. Prohibition of Harassment, Deceptive, or Abusive Practices (UDAP Compliance)

Origin Funding has zero tolerance for Unfair, Deceptive, or Abusive Acts or Practices (UDAP):

• No Harassment: Agents are trained to maintain a professional tone in all communications. Any form of harassment—whether verbal, written, or physical—towards clients or colleagues is strictly prohibited.
• No Deceptive Practices: We do not engage in misleading marketing or business practices. All information provided to clients is clear, accurate, and complete.
• No Abusive Practices: We ensure that all interactions with clients are conducted in a respectful and non-coercive manner.

5. Credit Checks and Privacy

At Origin Funding, we value your privacy:

• No Internal Credit Pulls: OF does not pull credit reports internally. We do not request, access, or evaluate your credit information without your explicit authorization and only when necessary as part of third-party financial services.

Note: We regularly review and update our Code of Conduct to ensure compliance with all federal, state, and local laws. If you have any questions regarding our policies or wish to discuss any aspect of our Code of Conduct, please feel free to contact us.