Legal Disclosures


Equal Credit Opportunity Act

The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant’s income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal agency that administers compliance with this law concerning Lower, is:

Federal Trade Commission, Equal Credit Opportunity

Pennsylvania and 6th Street
Washington, DC 20580
Home Mortgage Disclosure Act Notice

The HMDA data about our residential mortgage lending are available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age and income of applicants and borrowers; and information about loan approvals and denials. These data are available online at the Consumer Financial Protection Bureau’s Web site ( HMDA data for many other financial institutions are also available at this Web site.

USA Patriot Act – Customer Identification Requirements

In accordance with Section 326 of the USA Patriot Act, applicants for new accounts are requested to provide current picture identification that verifies identity including name, address and other identifying information.

Protection of our customer’s identity and confidentiality is our pledge to you. We proudly support all efforts to protect and maintain the security of our customers and our country.

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies every customer. What this means to you: When you apply for a loan, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see a valid form of identification; including, but not limited to your driver’s license or other identifying documents; Including, but not limited to:

  • A valid driver’s license
  • A valid state identification card
  • Military identification card
  • Unexpired passport
  • Non-resident alien card

Other forms of identification may be acceptable in certain situations.

Texas Mortgage Banker Disclosure (RE: Title 7 Texas Annotated Code §81.200(c))

Consumers wishing to file a complaint against a mortgage banker or a licensed mortgage banker residential mortgage loan originator should complete and send a complaint form to the Texas Department of Savings and Mortgage Lending, 2601 North Lamar, Suite 201, Austin, Texas 78705. Complaint forms and instructions may be obtained from the department’s website at A toll-free consumer hotline is available at 1-877-276-5550.

The department maintains a recovery fund to make payments of certain actual out of pocket damages sustained by borrowers caused by acts of licensed mortgage banker residential mortgage loan originators. A written application for reimbursement from the recovery fund must be filed with and investigated by the department prior to the payment of a claim. For more information about the recovery fund, please consult the department’s website at

Michigan Lending Laws Lending Disclaimer § 445.1602(10)

You have a right to submit a written application for a mortgage loan or a home improvement loan or to request written information concerning typical loan terms that we are currently offering on mortgage loans and home improvement loans. It is illegal to establish a minimum mortgage amount of more than $10,000.00 or a minimum home improvement loan of more than $1,000.00. It is illegal to deny a loan or vary the terms and conditions of a loan because of the racial or ethnic trends or characteristics of the neighborhood or the age of the structure, but not because of its physical condition. If your application for a loan is rejected, you have a right to a written statement of the reason for the rejection. If you are granted a loan but the amount required for downpayment, the interest rate, term to maturity, application procedure, or other terms or conditions of the loan vary from terms or conditions offered in other neighborhoods, you have a right to a written statement of the reasons for the variation. The rights described in this notice are set forth in and limited by this act.

If you believe that your rights under this act have been violated, you should contact the Department of Insurance and Financial Services:

DIFS – Department of Insurance and Financial
Services, Office of General Counsel

P.O. Box 30220
Lansing, MI 48909-7720
877 999 6442

Massachusetts Mortgage Review Board Notice

If you believe that we denied your mortgage application on the basis of the neighborhood where the property is located, you can appeal this denial to a Mortgage Review Board (the Board). The Board is made up of lenders and citizens from your area who are appointed by the Massachusetts Commissioner of Banks.

The Board will review the application to determine if it was denied because the property is located in a specific neighborhood or geographical area. If the Board finds that your loan was denied because of the property’s location, the Board will recommend that we reconsider the denial.

If you wish to appeal your denial, you must sign the statement below and return it in the enclosed addressed envelope to:

Administrative Secretary Mortgage Review Boards Division of Banks

1000 Washington Street, 10th Floor
Boston, MA 02118-6400

The confidential information in your mortgage application and appeal to the Board will be released only to the members of the Mortgage Review Board and the Administrative Secretary.

If you have any questions about this process, please contact the Administrative Secretary of the Board at the Division of Banks at (617) 956-1500.

The Board will notify you of its decision.

State of Illinois

Community Reinvestment Notice

The Department of Financial and Professional Regulation (Department) evaluates our performance in meeting the financial services needs of this community, including the needs of low-income to moderate-income households. The Department takes this evaluation into account when deciding on certain applications submitted by us for approval by the Department. Your involvement is encouraged. You may obtain a copy of our evaluation. You may also submit signed, written comments about our performance in meeting community financial services needs to the Department.

Mortgage Lending Criteria

The following provides, in general terms, underwriting criteria for a Mortgage Loan application. It is the policy of Lower to consider the creditworthiness of applicants and their ability the repay the loan for all Mortgage Loan applications. The primary factors used to determine creditworthiness include, but are not limited to, the following:

  • Credit history
  • Debt to income (DTI) ratio
  • Employment status (if applicable)
  • Projected monthly mortgage payment, and projected monthly payment on any simultaneous loan(s) secured by the same property
  • Cash reserves and other assets
  • Current income used to repay the loan
  • Collateral – Property condition and loan-to value (LTV)

Verification of Funds

Lower reserves the right to verify funds that are indicated to be used for the earnest money deposit, down payment, and closing costs, if applicable.


A written certified appraisal, agency approved equivalent or property inspection waiver is required for all mortgage loans. The purpose of an appraisal is to determine whether the collateral is of sufficient value to cover the requested loan. It is important to note that not all loan programs require an appraisal. Please consult your licensed mortgage loan officer.

Interest Rates

Interest rates are obtained and dependent on general market conditions. Contact Lower directly for current interest rates.


Loan programs and terms offered by Lower are established commensurate to the Government Sponsored Enterprises (GSE) guidelines and/or its investor criteria.

Flood Plain

If the real estate is located in a special flood hazard area, flood insurance will be required and must meet the following requirements: (1) The community must be participating in an approved flood program; (2) Insurance must be obtained in the amount at least equal to the lowest of (a) the unpaid principal balance of the new loan amount, (b) the replacement cost of the insurable improvements, or (c) the maximum amount available; and (3) A copy of the insurance policy must be submitted to Lower on or before closing.

Additional Criteria

All loans originated within agency conforming and high-balance loan limits must conform to standard automated underwriting system eligibility requirements as well as any additional requirements or overlays imposed by the specific loan program. All loan applications for non-agency loan programs will be subject to all guidelines and requirements specific to the particular loan program.

Where recommended or required by an investor, an automated underwriting system (AUS) submission will be considered alongside manual application of loan program guidelines. The decision to lend is based on the particular loan program guidelines and underwriting of pertinent documents supplied by the applicant or a third party. A title search will be performed on all loans prior to closing and Lower must secure a commitment for title insurance prior to closing.

Mortgage Disclosures and Closing Costs

Lower will provide a written loan estimate of closing costs when sufficient information regarding the mortgage loan is available and in accordance with all applicable laws and regulations. In addition, other Federal and State Disclosures are provided that contain information on important terms and conditions associated with loan applications. It is Lower’s primary goal to provide the best customer experience possible, and to accomplish that goal we want Lower customers to be well informed!

Construction-Permanent Admin Fee

This is a fee used to administer a construction-permanent loan. It includes monitoring draws and inspection fees during construction, as well as updates to the title of the property. This fee is reserved for transactions that allow you to finance the construction phase of your new home, after which, your loan converts into permeant financing with regular mortgage payments.