Compliance Center

Community Reinvestment Act (CRA) Compliance

HomeHero Alliance is designed from the ground up to generate Community Reinvestment Act credit for partner financial institutions. Our CRA compliance framework includes:

LMI Tract Targeting

HomeHero operates exclusively in Low-to-Moderate Income census tracts as defined by the FFIEC. Every origination is mapped to FFIEC LMI tract designations, ensuring CRA qualification at the loan level.

Auto-Generated CRA Documentation

For each loan originated through LendHero, HomeHero automatically generates a CRA documentation package including:

• Borrower income verification relative to area median income (AMI)
• FFIEC census tract classification and LMI designation
• Community development purpose narrative
• Property address and geocoded tract mapping
• Project scope and community benefit summary

CRA Exam Support

HomeHero provides partner banks with a dedicated CRA exam support package, including aggregate portfolio statistics, LMI penetration rates, and borrower demographic summaries prepared to OCC, FDIC, and Federal Reserve examination standards.

CRA Investment Channel

In addition to lending, HomeHero structures its operations to support CRA investment credit — including investments in HomeHero itself as a CDFI-aligned community development entity.

Home Mortgage Disclosure Act (HMDA)

Renovation loans facilitated through LendHero are captured in HMDA-reportable format where applicable. HomeHero provides partner lenders with:

• Monthly HMDA LAR data exports in CFPB-required format
• Geocoded property location data at the census tract level
• Borrower demographic data fields (collected in compliance with ECOA/Regulation B)
• Loan purpose, action taken, and denial reason codes
• Rate spread and HOEPA status determination support

HomeHero does not submit HMDA data on behalf of lending partners — that obligation remains with the licensed lender. HomeHero provides the underlying data necessary for accurate reporting.

CDFI Mission Alignment

HomeHero is a mission-aligned community development entity. Our operations directly serve the CDFI community's target populations:

• Low-to-moderate income homeowners in economically distressed communities
• Underbanked borrowers underserved by traditional renovation lending
• Communities experiencing disinvestment and deferred maintenance cycles

CDFI Fund Reporting Support

CDFIs using HomeHero as a deployment channel receive impact reporting metrics formatted for CDFI Fund annual reports, including:

• Jobs created or retained (contractor employment data)
• Number of LMI borrowers served and demographic breakdown
• Dollar volume of financing deployed by census tract
• Affordable housing units preserved or improved
• Community development impact narratives

Capital Stacking Compliance

HomeHero supports layered capital structures combining CDFI first-loss capital, bank senior debt, OZ equity, and NMTC proceeds. Our compliance team ensures each layer meets its respective program requirements.

Opportunity Zone Compliance

HomeHero tracks Opportunity Zone compliance metrics for Qualified Opportunity Fund (QOF) partners investing in residential renovation projects within designated OZ census tracts.

OZ 2.0 Updates (OBBBA 2025)

The One Big Beautiful Bill Act made the OZ program permanent and introduced OZ 2.0 provisions effective 2026. HomeHero's compliance framework incorporates:

• Rolling 5-year gain deferral tracking for fund investors
• 10% basis step-up documentation at the property level
• Rural OZ fund identification and enhanced incentive tracking
• Re-designation monitoring beginning July 1, 2026

Property-Level Tracking

For each OZ project, HomeHero documents:

• Original use designation (new construction vs. substantial improvement)
• Substantial improvement test: renovation spending vs. original acquisition basis
• QOZ Business Property qualification status
• Timeline documentation for the 31-month working capital safe harbor

New Markets Tax Credits (NMTC) & CDEs

Following the NMTC program's permanent authorization in the One Big Beautiful Bill Act, HomeHero has developed a CDE partnership program for Community Development Entities deploying NMTC allocations through the platform.

Community Benefit Tracking

HomeHero provides CDEs with the community benefit documentation required by Treasury's NMTC program, including:

• Low-income community (LIC) census tract verification for each project
• Community benefit commitments and outcomes tracking
• Qualified Low-Income Community Investment (QLICI) documentation
• Substantially all investment test compliance monitoring
• Annual impact reports for Treasury compliance submissions

Streamlining Initiative

HomeHero is developing standardized documentation packages to reduce NMTC deal transaction costs for smaller renovation projects — a key barrier to NMTC deployment below $5M.

Fair Lending & Equal Credit Opportunity

HomeHero is committed to fair and equitable access to renovation financing. Our fair lending framework includes:

Y-Score Underwriting Model

HomeHero's proprietary Y-Score model supplements traditional credit scoring for LMI borrowers. The model has been:

• Validated against fair lending testing protocols to identify and mitigate disparate impact
• Reviewed for prohibited basis factors (race, color, religion, sex, national origin, familial status, disability, age)
• Documented with model governance records available for regulatory review
• Tested for disparate impact outcomes across protected classes

Adverse Action Notices

Borrowers who are declined for renovation financing through LendHero receive adverse action notices compliant with ECOA/Regulation B and FCRA requirements, including specific reason codes and credit reporting agency contact information.

Non-Discrimination Policy

HomeHero does not discriminate in the provision of platform services on the basis of race, color, religion, sex, national origin, disability, familial status, age, or any other protected characteristic under applicable law.

Consumer Protection

Disclosure Requirements

HomeHero provides clear, plain-language disclosures to homeowners at each stage of the process, including:

• Platform fees and service charges prior to project initiation
• Loan APR, total cost, and repayment terms for all financing products
• Contractor background check summaries and rating information
• HeroVerify inspection scope and limitations
• Escrow terms and conditions before fund deposit

Contractor Screening Disclosures

HomeHero verifies contractor licenses and insurance but does not guarantee contractor performance. Homeowners are informed of this limitation and encouraged to review contractor profiles, ratings, and portfolio materials before selection.

Complaint Resolution

HomeHero maintains a consumer complaint program that provides written acknowledgment within 5 business days and resolution within 30 days. Unresolved complaints may be escalated to state regulatory agencies or the CFPB.

Data & Financial Privacy

Financial data privacy is governed by the Gramm-Leach-Bliley Act (GLBA) and our Privacy Policy. Key protections include:

• Annual GLBA privacy notices to all borrowers and financing applicants
• Opt-out rights for non-public personal information sharing with unaffiliated third parties
• Safeguards Program compliant with GLBA and FTC regulations
• Data minimization — we collect only information necessary for the services requested
• Third-party vendor data security requirements via contractual controls

For the full data privacy framework, see our Privacy Policy.

Contractor Compliance

HomeHero maintains a rigorous contractor compliance program to protect homeowners and platform integrity:

• License verification: State contractor license validated against state licensing board databases at onboarding and annually
• Insurance verification: General liability ($1M minimum) and workers' comp certificates reviewed at onboarding and upon renewal
• Background checks: Criminal history, sex offender registry, and business entity checks conducted by a FCRA-compliant consumer reporting agency
• Ongoing monitoring: License status and insurance coverage monitored continuously; contractors are suspended if coverage lapses
• Milestone accountability: HeroVerify inspection results are used to maintain contractor performance scores; poor performance triggers review and potential removal

Anti-Money Laundering & Fraud Prevention

HomeHero maintains an anti-money laundering and fraud prevention program commensurate with our risk profile:

• Customer Identification Program (CIP) for all account holders
• OFAC sanctions screening for all users and contractors at onboarding and on a scheduled basis
• Transaction monitoring for unusual patterns in escrow disbursements
• Suspicious Activity Reporting (SAR) procedures for reportable transactions
• Fraud detection systems monitoring for account takeover, identity theft, and payment fraud

Accessibility

HomeHero is committed to making our platform accessible to users with disabilities. We are working toward WCAG 2.1 Level AA compliance across all platform surfaces. Current efforts include:

• Keyboard navigation support throughout the platform
• Screen reader compatibility for core workflows
• Sufficient color contrast ratios in platform UI
• Alt text for all meaningful images
• Accessible form labels and error messages

To report an accessibility issue or request an accommodation, contact accessibility@homeheroalliance.com.

Regulatory Reporting

HomeHero maintains a regulatory reporting calendar and compliance management system. The following reports are generated and provided to applicable partners:

• Monthly: HMDA LAR data exports to lending partners; CRA transaction logs; escrow reconciliation
• Quarterly: CDFI Fund impact metrics; OZ property status updates; contractor compliance audit results
• Annually: CRA exam support package; GLBA privacy notice distribution; NMTC community benefit reports; full platform compliance review
• As needed: Adverse action reporting; SAR filings; regulatory examination support materials

Compliance Contacts

For compliance inquiries, regulatory requests, or to report a concern: