ADC REALTY & INVESTMENTS GROUP INC.

AFRICAN DREAM BIG CORPORATION 

PRIVACY POLICY

In Compliance of:

THE GRAMM-LEACH-BLILEY ACT - FINANCIAL MODERNIZATION

Report on Title V- Privacy and Restrictions on Disclosing

Nonpublic Personal Information

DISCLOSURE OF NONPUBLIC PERSONAL INFORMATION - GENERAL PURPOSE:

In compliance with Title V of The Financial Modernization Act, ADC Realty & Investments Group Inc. has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers' nonpublic personal information, as that term is defined. The Federal Trade Commission is the regulatory body governing non-depository institutions (mortgage bankers) relative to this Act.  ADC Realty & Investments Group Inc Privacy Policy has been drafted in compliance with the requirements of this Act, which has the purpose of:

• ensuring the security and confidentiality of customer records and information;

• protecting against any anticipated threats or hazards to the security or integrity of such records; and

• Protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any customer.

PRIVACY POLICY (Loans and Real Estate Transactions):

ADC Realty & Investments Group Inc will not, directly or through its affiliates disclose to a nonaffiliated third party any nonpublic personal information without first providing notice to the consumer and affording them the opportunity to “opt out of the sharing arrangement.

ADC Realty & Investments Group Inc.'s current policy is NOT to share any non-public personal information with any nonaffiliated third party source except as necessary for the express intention of processing and closing a borrower’s loan application and the servicing and selling of a borrower’s loan.  This generally includes obtaining information from credit agencies, verification of assets, income, or employment, or sharing information with third-party service providers for the hazard, flood, or private mortgage insurance coverage, servicing, auditing, and enforcement of the Note and Deed of Trust.

At this time, the “opt-out” provision is not applicable due to our policy of NOT sharing any non-public personal information with any nonaffiliated third party except for the purposes indicated above. The definition of non-personal public information includes not only privately obtained borrower information such as social security numbers, credit histories, depository, and employment information but also includes customer lists, which include loan numbers and other non-public data.

No employee is authorized to share any borrower’s non-public personal information for the purpose of solicitation for additional products or services or any other purpose.

SECURITY AND CONFIDENTIALITY:

Only those employees whose specific job duties require access to the client’s transaction files and therefore their non-public personal information may be in possession of any transaction file. Branch Managers are to ensure there is unauthorized access to transaction files in their branch offices.

ADC Realty & Investments Group Inc. Employees/Independent Contractors are given this notice:

Privacy Protection for Customers to Thwart Fraudulent Access to Financial Information:

Title V Subpart B provisions addressing Fraudulent Access to Financial Information’ established a general rule prohibiting persons from obtaining or attempting to obtain, or disclosing or attempting to cause to be disclosed to any person, a financial institution’s “customer’s information” by any means of false pretenses. Anyone who knowingly and intentionally violates Section 521 is subject to fines, imprisonment, or both.

The scope of “false pretenses” encompasses the following activities:

-  Making a false, fictitious, or fraudulent statement or representation to an officer, employee, or agent of a financial institution;

-  Making a false, fictitious, or fraudulent statement or representation to a customer of a financial institution; and

-  Providing any documentation to an officer, employee, or agent of a financial institution, knowing that the document is forged, counterfeit, lost, stolen, was fraudulently obtained or contains a false, fictitious, or fraudulent statement or representation.

Storage of Transaction Files:

Closed or canceled transaction files are to be maintained in a secured storage location.

Destruction of Transaction Files:

When transaction files are eligible to be destroyed due to “loan payoff” (and after the applicable regulatory agency-required retention period has expired), transaction files are to be shredded and NOT just discarded, this also applies to duplicate files maintained in a branch office.

Third-Party Service Providers:

Third-party service providers are required to execute a Confidentiality Agreement or Clause as part of their contract with ADC Realty & Investments Group Inc. in compliance with said Act.  “Grand-fathered” contracts, those in effect as of April 1, 2012, will be given until new updates become available, to comply with the said amendment.

Employee/Contractor Education:

All employees/Independent Contractors are required to read the CL Privacy Policy and acknowledge receipt of said policy. Acknowledgments are to be maintained in the employee’s/Contractor's personnel file in Human Resources. Employees/Contractors who violate all or any portion of this policy are subject to termination.

PRIVACY POLICY STATEMENT:

Initial Disclosure:

The ADC Realty & Investments Group Inc. Privacy Policy Statement is to be provided to the Sellers, buyers, lessees, lessors, and borrowers commencing with transaction application received on or after April 1, 2012, as follows: 

Retail Loan Originations / Listings / prospective buyers:

• The interviewer in the transaction application process must give this Privacy Policy Statement to the clients to be executed at the time the transaction application is taken face-to-face.  A copy must be given to the client for their records and a copy retained in the branch file and a copy must be included in the transaction package upon submission to the transaction coordinator.

• If the transaction Application is taken by phone or by mail, this Privacy Policy Statement is to be mailed to the client with the initial Truth-In Disclosure and other applicable transaction disclosures. A copy is to be retained in the branch file and a copy must be included in the transaction package upon submission to the transaction coordinator. The cover letter that is sent with the transaction disclosures must reflect the inclusion of this document.

Wholesale Loan Originations (Loan Transactions only):

The Privacy Policy Statement is to be mailed to the borrower with the initial Truth-In-Lending Disclosure and other applicable origination disclosures. A copy is to be retained in the storage file.

Annual Disclosure (Loan Transactions only):

The Privacy Policy Statement is to be re-disclosed (by mail) annually for those loans ADC Realty & Investments Group Inc. continues to service beyond 12 months from the loan closing date.