Lender Code of Conduct

Our standards for professional, ethical, and borrower-focused lending practices

Version 1.1 — Effective March 1, 2026

HomeTurf is committed to creating a marketplace where borrowers can trust the lenders they work with. This Code of Conduct establishes the standards we expect from all lenders on our platform across all four auction modes: Purchase, Refinance, Pre-Approval, and Beat My Rate. Adherence to this code is mandatory and is monitored through our performance tracking system.

Core Principles

Accuracy

All bids must reflect rates and terms you can reasonably deliver based on the borrower's disclosed information. Quote what you can honor.

Transparency

Disclose all fees, conditions, and requirements clearly and upfront. No hidden costs, no surprise conditions, no fine print traps.

Responsiveness

Respond promptly to borrowers who accept your bids. You are required to make initial contact within 36 hours and maintain ongoing timely communication.

Respect

Treat all borrowers with professionalism, courtesy, and respect regardless of their financial situation or loan amount.

Compliance

Follow all applicable federal and state lending regulations including RESPA, TILA, ECOA, Fair Housing Act, and state-specific requirements.

Integrity

Compete fairly on the merits of your rates and service. Win business through excellence, not manipulation or deception.

Bid Commitment Standards

When you submit a bid on HomeTurf (any auction mode), you are making a commitment to the borrower:

Quote Validity

Your quoted rate represents a good-faith estimate valid for 36 hours after the borrower selects your bid. This is an offer validity window — not a rate lock. You are responsible for contacting the borrower, verifying their information, and formally locking the rate according to your standard procedures.

Fee Accuracy

All closing costs and fees are accurate estimates based on the information provided. Final fees will comply with TRID tolerance requirements (0% for lender fees, 10% for third-party services).

Good Faith Intent

You intend to honor your quoted terms if the borrower qualifies through standard underwriting. Bids are not teaser rates designed to be changed later.

36-Hour Response Commitment

You will contact the borrower within 36 hours after your bid is selected to begin the application process. Failure to respond within this window is a violation of your commitment and may result in enforcement action.

Rate Lock Responsibility

You are solely responsible for formally locking the borrower's rate once you have verified their information and they have submitted a complete application. Market rates change daily — prompt processing protects the borrower's quoted terms.

Understanding Rate Quotes vs. Rate Locks

Important Distinction

A bid on HomeTurf is a rate quote, not a rate lock. Understanding this distinction is critical for maintaining borrower trust and regulatory compliance.

Rate Quote (Your Bid)

  • • A good-faith estimate based on disclosed borrower information
  • • Valid for 36 hours after borrower selection
  • • Subject to verification of borrower-provided information
  • • Not a binding commitment until formal lock is issued

Rate Lock (Your Responsibility)

  • • A formal commitment from you to honor a specific rate
  • • Issued after you verify borrower information
  • • Typically valid for 30-60 days depending on your policies
  • • Subject to your standard lock terms and conditions

Your Obligation: Contact the borrower within 36 hours, process their application promptly, and lock the rate in accordance with your standard procedures once you have verified their eligibility. Unreasonable delays that result in rate increases may be considered a violation of this Code of Conduct.

Prohibited Practices

The following practices are strictly prohibited and will result in enforcement action:

Bait and Switch

Quoting attractive terms with the intent to change them after acceptance

Ghosting

Failing to contact the borrower within 36 hours after your bid is selected

Pressure Tactics

Using high-pressure sales techniques or artificial urgency

Discrimination

Treating borrowers differently based on protected characteristics

Kickbacks

Paying or receiving referral fees in violation of RESPA

Misleading Information

Providing false statements about rates, terms, or qualifications

Off-Platform Contact

Contacting borrowers outside the platform before winning their auction

Intentional Delay

Deliberately delaying rate lock to capture higher rates due to market movement

Data Harvesting

Collecting borrower data for purposes other than the transaction at hand

Performance Tracking

To maintain trust and transparency, we track and may display the following metrics to borrowers:

Closing Rate

Percentage of accepted bids that successfully close. A key indicator of whether you can deliver on your quotes.

Terms Honored Rate

Percentage of loans where final terms matched the original bid. Shows consistency between quotes and outcomes.

Response Time

Average time to contact the borrower after your bid is selected. Target is within 36 hours; faster is better.

Borrower Ratings

Average rating from borrowers who completed transactions with you. Direct feedback on service quality.

Earning Badges

Lenders with excellent performance earn badges displayed to borrowers: Verified, Responsive, High Close Rate, Terms Honored, and Borrower Favorite.

Enforcement

Violations of this Code of Conduct are addressed through progressive discipline:

Offense LevelFirstSecondThird
MinorWarning7-day probation30-day suspension
Moderate7-day probation30-day suspension90-day suspension
Severe30-day suspension90-day suspensionPermanent removal
CriticalImmediate permanent removal

Probation: During probation, your account displays a visible "Under Review" badge to borrowers, and you may have reduced bid limits.

Suspension: During suspension, you cannot submit bids or access the platform. Existing winning bids remain your responsibility.

Permanent Removal: Reserved for fraud, material misrepresentation, or regulatory violations. May include reporting to applicable regulatory authorities.

Report Violations

If you observe another lender violating this Code of Conduct, or if you have concerns about practices on the platform, please report it:

Email: support@hometurfus.com

All reports are reviewed by our compliance team. You may report anonymously.

By bidding on HomeTurf, you acknowledge that you have read, understand, and agree to abide by this Lender Code of Conduct. This code is incorporated into and forms part of our Terms of Service.

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