Wellthi Technologies Inc Fair Lending Policy Statement
Wellthi Technologies Inc (“Wellthi”) is committed to the principles of fair, equitable, and responsible lending. Wellthi believes that every customer should have equal access to credit in accordance with their creditworthiness and should not be discriminated against on any prohibited basis. Wellthi has partnered with the D.C. government under the D.C. Capital Connector program, through which Wellthi provides the underlying technology that connects small business owners (each a “prospective borrower”) with prospective lenders in the program (each a “Partner Lender”). Wellthi’s recommendations for prospective borrowers are based on a number of considerations, including the minimum eligibility requirements and underwriting standards of the Partner Lenders. When matching prospective borrowers with Partner Lenders, Wellthi does not take into consideration any of the following prohibited factors:
Age (other than to confirm that the customer has the legal capacity to contract)
The fact that the customer receives income from a public assistance program
The fact that the applicant has in good faith exercised any right under the Consumer Credit Protection Act
Wellthi similarly will not discourage any customer from seeking credit or submitting an application to a potential lender based on any of the above prohibited factors. These commitments apply to all areas of Wellthi’s activities, including its advertising, its oral and written communications with customers and prospective customers, its oral and written communications with lending partners, and its internal business operations.
Wellthi’s policy of non-discrimination and non-discouragement includes both direct use of prohibited factors (“disparate treatment”), as well as the use of words or actions that are not designed to discriminate or discourage but that may have the unintended effect of doing so (“disparate impact”). For example, Wellthi will endeavor to use inclusive graphics and language in its advertising so as not to give the incorrect impression that certain people or classes of people are less welcome than others. Similarly, Wellthi will not use analytic factors that may serve as proxies for protected categories without ensuring that such use does not create a material risk of impermissible discrimination.
Each Wellthi employee is expected to read and be familiar with this policy and its requirements. Wellthi will not tolerate behavior by its employees or third parties that is inconsistent with this policy or that is discriminatory, unfair, or harmful to Wellthi’s customers. Failure to comply with this policy may result in disciplinary action.
Any questions about this policy should be directed to the Chief Compliance Officer.