6.12 Regulators, Government Officials – Inquires/Visits/Subpoenas

Any inquiry by a government official, whether by telephone, letter, or in person, should immediately be forwarded to the Broker or Manager. In the absence of the Broker or Manager, the name of the official and agency or department he/she represents should be obtained. Then, the owner or other officer of the Company should be contacted. If none of these persons are available, the person receiving the inquiry should immediately contact the Company Compliance Director who will then contact the company attorney. In situations where neither the Broker or Manager nor an officer of the Company are available and the inquiry is of an in-person nature, the person receiving the inquiry should not allow any representative from a local, state or federal office to see any files or any information maintained in the office unless presented with a valid search warrant signed by a federal judge or a judge of the county in which the office is located, or unless the government official is a representative of the State regulator or Real Estate Commission or State Department. The person should refuse to answer any questions of such a representative official unless the company's attorney has authorized the person to answer.

If a process server appears in the office with a subpoena for the Company, any employee or agent/loan officer should accept it. Once accepted, it should immediately be turned over to the Broker or Manager. The Broker or Manager should immediately contact the owner or other officer of the Company. In the absence of any of these persons, the Broker or Manager should contact the Company's attorney. If the process server asks for a specific person, only that specific person may accept the subpoena. If that person is not in the office, the person receiving the inquiry should not volunteer any information about the person requested and should not give out home phone numbers or home addresses, even if asked. Refer the inquiry to the Broker or Manager immediately.