Privacy Policy

MOR Financial Services, Inc.

Effective Date: June 24, 2026  |  Last Updated: June 24, 2026

MOR Financial Services, Inc. is a California-licensed private mortgage lender (California DRE #01860343, NMLS #362324) headquartered in Los Angeles, California. This Privacy Policy explains how we collect, use, share, and protect personal information when you:

• Visit www.morfinancial.com or any related MOR Financial web property;
• Apply for, inquire about, or obtain a loan from MOR Financial;
• Invest in or inquire about the MOR Investment Fund, LLC or our trust deed investment offerings;
• Communicate with us by phone, email, text, or in person;
• Engage with us as a broker, vendor, contractor, or business partner.

This Policy applies to personal information collected through these channels. Where we provide a financial product or service, additional disclosures under the federal Gramm-Leach-Bliley Act (GLBA) and the California Financial Information Privacy Act (CFIPA) also apply, summarized in Sections 15 and 16.

2. Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information, as defined under the CCPA/CPRA:

• Identifiers: name, postal address, email address, phone number, IP address, account login, government-issued ID number (e.g., driver’s license).
• Customer records: information you provide in a loan application or investor subscription document, including signature, employment information, and financial account information.
• Financial information: credit history, income, assets, liabilities, banking information, tax records, payment history, and loan performance information.
• Commercial information: records of products or services purchased or considered (e.g., loan products inquired about), transaction history.
• Internet activity: browsing history on our website, interaction with our content, device and browser information, referring URLs.
• Geolocation: general location based on IP address. We do not collect precise geolocation through our website.
• Professional or employment information: employer, position, professional licenses, and broker affiliation.
• Inferences: conclusions drawn from the above to assess creditworthiness, investment suitability, or service preferences.
• Sensitive Personal Information: see Section 3 below.

3. Sensitive Personal Information

As a mortgage lender and investment fund manager, we necessarily collect sensitive personal information under the CPRA, including:

• Social Security number, driver’s license number, state ID number, or passport number;
• Financial account numbers (with or without credentials, including login info if you use our borrower or investor portals);
• Precise financial information necessary to evaluate creditworthiness;
• Where applicable, information necessary to verify accredited investor status for investment offerings.

We collect and use this sensitive personal information only for purposes permitted under CPRA Section 1798.121(a), including to perform the financial services you have requested, to detect and prevent fraud, to comply with legal obligations, and to maintain the security and integrity of our systems. We do not use sensitive personal information to infer characteristics about you or for cross-context behavioral advertising.

4. Sources of Information

We collect personal information from the following categories of sources:

• Directly from you when you submit a loan inquiry, application, or investor subscription, or communicate with us;
• From mortgage brokers or referral partners who submit loan scenarios on your behalf;
• From consumer reporting agencies (e.g., credit bureaus) to evaluate creditworthiness;
• From public records and licensed data sources (e.g., property records, title companies, government databases);
• From service providers who assist with appraisal, escrow, title, document signing, or loan servicing;
• From our website through cookies, analytics tools, and similar technologies (see Section 8).

5. How We Use Information

We use personal information for the following business purposes:

• To evaluate, underwrite, document, fund, and service loans;
• To evaluate investor suitability, verify accreditation, and administer investments;
• To process payments, distributions, and other financial transactions;
• To communicate with you about your application, loan, account, or inquiry;
• To respond to your questions, requests, or complaints;
• To operate, maintain, secure, and improve our website and services;
• To detect, prevent, and investigate fraud, money laundering, identity theft, and other unlawful activity;
• To comply with applicable laws, regulations, and lawful requests from government authorities (including the California DRE, the NMLS, the SEC, the CFPB, and other regulators);
• To enforce our agreements, protect our rights and property, and protect the safety of others;
• For internal record-keeping, audit, accounting, and tax purposes.

We do not use personal information for purposes materially different from those listed above without providing notice and, where required, obtaining your consent.

6. How We Share Information

We share personal information only as needed to provide our services, comply with the law, and operate our business. Specifically, we may share information with:

• Service providers and vendors bound by written contracts that limit their use of your information to the services they provide on our behalf. Examples include loan servicing platforms (The Mortgage Office), document e-signature platforms, escrow and title companies, appraisers, accounting firms, IT and security vendors, and outside counsel.
• Affiliates of MOR Financial in connection with the financial products or services you have requested (e.g., MOR Investment Fund, LLC for trust deed and fund investments).
• Regulators, courts, and law enforcement as required by law, subpoena, or other valid legal process.
• Successors in interest in the event of a merger, acquisition, financing, reorganization, or sale of business assets, subject to the terms of this Policy and applicable law.
• Counterparties to your transaction as necessary to close, fund, document, or service your loan (e.g., your title company, your real estate attorney, your broker).

We do not share nonpublic personal information with non-affiliated third parties for marketing purposes. See Section 15 (GLBA Notice) and Section 16 (CFIPA) for additional disclosures specific to financial information.

7. Sale and Sharing of Personal Information

We do not sell your personal information.

Under the CPRA, “sharing” includes disclosing personal information to a third party for cross-context behavioral advertising, whether or not for monetary consideration. Our website uses certain analytics and advertising technologies (described in Section 8) that may result in personal information being disclosed to those providers for advertising purposes. To the extent that any such disclosure constitutes “sharing” under the CPRA, you have the right to opt out at any time.

To exercise your right to opt out, send a request to [email protected]. We also honor recognized Global Privacy Control (GPC) signals (see Section 12).

8. Cookies & Tracking

Our website uses cookies, pixels, and similar technologies to operate the site, analyze usage, and (in some cases) deliver advertising. Categories of technologies used include:

• Strictly necessary: required for the website to function (e.g., session cookies, security tokens).
• Analytics: Google Analytics and Google Site Kit to understand site usage and improve content.
• Tag management: Google Tag Manager to deploy and manage other tags.
• Advertising / Social: Meta (Facebook) Pixel and related social media trackers.

You can manage cookies through your browser settings, and you can opt out of cross-context behavioral advertising as described in Section 7. We honor Global Privacy Control (GPC) signals as a valid opt-out (see Section 12).

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, accounting, and regulatory requirements applicable to mortgage lenders and investment fund managers. Specific retention periods include:

• Loan files and supporting documents: retained for at least the period required by California DRE, NMLS, federal, and state lending regulations (generally 3–7 years from loan payoff or final action, longer where required).
• Investor records: retained for at least the period required by SEC and California Department of Financial Protection and Innovation (DFPI) regulations.
• Tax and accounting records: retained per IRS and California Franchise Tax Board requirements.
• Website and analytics data: retained for the period specified by the relevant analytics provider, generally not longer than 26 months.
• Consumer requests: retained for at least 24 months as required by the CCPA.

When personal information is no longer needed, we securely delete or de-identify it, except where retention is required by law.

10. Your Privacy Rights

If you are a California resident, you have the following rights under the CCPA/CPRA. Please note: certain personal information collected in connection with a financial product or service is exempt from CCPA under the GLBA exemption (see Section 15). The rights below apply to personal information that is not covered by that exemption (e.g., website browsing data, marketing communications, and information from individuals who are not customers).

Right	What it means
Right to Know	Request that we disclose the categories of personal information we have collected, the sources, the purposes, the categories of third parties with whom we share it, and the specific pieces of personal information we have collected about you.
Right to Delete	Request that we delete personal information we have collected from you, subject to legal exceptions (e.g., we must retain loan records).
Right to Correct	Request that we correct inaccurate personal information.
Right to Opt Out of Sale/Sharing	Direct us not to sell or share your personal information.
Right to Limit Use of Sensitive Personal Information	Direct us to use sensitive personal information only for purposes permitted under CPRA Section 1798.121(a).
Right to Non-Discrimination	We will not discriminate against you for exercising your rights, including by denying services, charging different prices, or providing a different level of service.
Right to Appeal	If we deny a request, you may appeal that decision (see Section 11).

11. How to Exercise Your Rights

To exercise any of the rights described above, contact us by one of the following methods:

• Email: [email protected] with the subject line “Privacy Request”
• Phone: 1 (877) 667-1300
• Mail: Privacy Officer, MOR Financial Services, Inc., US Bank Tower, 633 W. 5th Street, FL 26, Los Angeles, CA 90071

Identity verification

To protect your information, we will verify your identity before fulfilling a request. The level of verification depends on the sensitivity and risk of the request. We may ask you to confirm information already in our records or, for sensitive requests, to provide a signed declaration under penalty of perjury.

Authorized agents

You may use an authorized agent to submit a request on your behalf. The agent must provide written permission from you and prove their own identity. We may also require you to verify your identity directly and confirm that you authorized the agent.

Response timing

We will confirm receipt of your request within 10 business days and respond substantively within 45 calendar days. We may extend this period by an additional 45 days where reasonably necessary, with notice to you.

Appeals

If we deny your request in whole or in part, you may appeal by replying to our denial within 30 days or by sending a new request marked “Appeal” to [email protected]. We will respond to appeals within 60 days.

12. Global Privacy Control and Opt-Out Preference Signals

We honor opt-out preference signals sent through Global Privacy Control (GPC) or any other recognized browser-level privacy signal. If you visit our website with GPC enabled, we will treat that signal as a valid request to opt out of any “sharing” of personal information for that browser and device, to the extent applicable.

13. Automated Decision-Making Technology (ADMT)

MOR Financial uses software tools, including automated underwriting platforms, credit scoring models, and risk-assessment tools, to assist in evaluating loan applications and managing risk. These tools assist our underwriters; final loan decisions are made by qualified MOR Financial personnel who review the file and exercise independent judgment. We do not make loan approval, denial, pricing, or significant decisions solely based on automated processing without meaningful human involvement.

If, in the future, we use ADMT to make decisions producing legal or similarly significant effects without meaningful human involvement, we will provide pre-use notices, opt-out mechanisms, and access rights as required by the CPRA ADMT regulations effective January 1, 2027.

14. Children’s Privacy

Our services are not directed to children under 16, and we do not knowingly collect personal information from children under 16.

• We do not sell or share the personal information of consumers under 16 without their affirmative authorization (or, for consumers under 13, the affirmative authorization of a parent or guardian).
• If you believe we have collected personal information from a child under 13 without parental consent, please contact us at [email protected] and we will delete it.

15. GLBA Notice for Financial Customers

This section is the privacy notice required under the federal Gramm-Leach-Bliley Act (GLBA), 15 U.S.C. § 6801 et seq., and Regulation P (12 C.F.R. Part 1016), for individuals who are or become customers of MOR Financial Services, Inc.

Information we collect

We collect nonpublic personal information (“NPI”) about you from:

• Applications and other forms (e.g., name, address, SSN, income, employment);
• Transactions with us, our affiliates, or others (e.g., account balances, payment history);
• Consumer reporting agencies (e.g., credit reports);
• Public records and other sources used to verify information.

Information we disclose

We disclose NPI only as permitted by law, including to:

• Service providers that perform services for us (subject to confidentiality obligations);
• Counterparties necessary to process or service your transaction (e.g., escrow, title, appraisers);
• Regulators, courts, and law enforcement when legally required;
• Our affiliates in connection with the financial products or services you have requested.

We do not disclose NPI to non-affiliated third parties for marketing purposes. Because we do not share NPI in ways that would trigger an opt-out right under GLBA, no GLBA opt-out notice is required. California residents have additional rights under the California Financial Information Privacy Act (see Section 16).

How we protect information

We maintain administrative, technical, and physical safeguards designed to protect NPI in compliance with the GLBA Safeguards Rule (16 C.F.R. Part 314) and applicable state law.

Former customers

If you cease to have a customer relationship with us, we continue to handle NPI about you in accordance with this Policy.

16. California Financial Information Privacy Act (CFIPA)

If you are a California resident and a customer of MOR Financial, the California Financial Information Privacy Act (Cal. Fin. Code § 4050 et seq.) provides you with additional privacy protections beyond the federal GLBA.

Under CFIPA, a California financial institution generally may not share NPI with non-affiliated third parties without your prior affirmative (“opt-in”) consent, subject to specific exceptions for ordinary servicing of your account. As described in Section 15, MOR Financial does not share NPI with non-affiliated third parties for marketing purposes, and our sharing with affiliates is limited to what is reasonably necessary to provide the financial products and services you have requested.

17. California Shine the Light

California Civil Code § 1798.83 permits California residents to request, once per calendar year, information about disclosures of personal information by MOR Financial to third parties for the third parties’ direct marketing purposes during the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes. California residents may submit a Shine the Light request to [email protected].

18. Your Rights Under Other State Privacy Laws

Residents of certain other states (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Indiana, Delaware, New Hampshire, New Jersey, Minnesota, Maryland, Kentucky, Rhode Island, and Nebraska) have privacy rights under their respective state laws. These rights generally include the right to access, correct, delete, and obtain a portable copy of certain personal information, and to opt out of sale, targeted advertising, and certain profiling.

To exercise rights under any applicable state privacy law, contact us using the methods in Section 11. Where required, we will provide an appeal process specific to your state.

Note: Most personal information we hold about loan customers and investors is collected in connection with a financial product or service and is therefore subject to the GLBA and applicable state financial information privacy laws rather than general consumer privacy laws.

19. SMS / Text Messaging

MOR Financial Services, Inc. offers a one-to-one conversational text messaging service for customers, borrowers, brokers, investors, and vendors. The full terms of this service are described at https://www.morfinancial.com/sms-policy/, which is incorporated into this Privacy Policy by reference. Key points are summarized below.

Type of messages

If you opt in, you will receive conversational account notification and customer service messages from MOR Financial employees regarding your inquiry, loan, account, or business relationship. We do not send marketing, promotional, or automated SMS messages through this service.

Opt-in

We collect SMS opt-ins verbally at our physical office locations or over the phone. When you provide your mobile number, we inform you that by doing so you consent to receive conversational SMS messages from MOR Financial, that message and data rates may apply, that frequency varies, and that you may reply HELP for support or STOP to unsubscribe. Phone numbers will not be shared with third parties.

Frequency and cost

This service is for person-to-person communication between you and MOR Financial employees, so message frequency varies depending on your transaction or inquiry. We do not charge you for messages, but message and data rates may apply through your wireless carrier.

Opt-out

You may opt out of SMS messages at any time by replying STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE to any message. After opting out, you will receive a confirmation message and will not receive further texts from that number. Reply HELP for support, or contact us at (213) 784-0737 or [email protected].

Mobile information sharing

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent are not shared with any third parties. Information collected through the SMS service is used only to transmit your mobile messages and respond to you, and may be shared only with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages.

Full SMS terms

For the complete SMS Text Messaging Terms of Use and Privacy Policy, please visit www.morfinancial.com/sms-policy.

20. Fair Credit Reporting Act (FCRA) Notice

To evaluate loan applications, we obtain consumer reports from consumer reporting agencies (commonly known as “credit bureaus”) in accordance with the federal Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. If we take adverse action based in whole or in part on information in a consumer report, we will provide you with the notice required by the FCRA, including the identity of the consumer reporting agency and your right to obtain a free copy of your report from that agency.

21. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, disclosure, or destruction. These safeguards include access controls, encryption in transit and at rest where appropriate, network security measures, employee training, vendor due diligence, and incident response procedures. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

22. Data Breach Notification

If we determine that a data breach has occurred affecting personal information, we will notify affected individuals and applicable regulators in accordance with California Civil Code § 1798.82 and other applicable federal and state laws. Notifications will be made without unreasonable delay and in the manner required by law.

23. Third-Party Links

Our website may contain links to third-party websites, applications, and services that are not controlled by MOR Financial. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party website you visit.

24. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other reasons. We will post the updated Policy on our website and update the “Effective Date” and “Last Updated” dates at the top. Material changes will be communicated to customers as required by applicable law. We review this Policy at least once every 12 months.

25. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us:

• Email: [email protected]
• Phone: 1 (877) 667-1300
• Mail: Privacy Officer
  MOR Financial Services, Inc.
  US Bank Tower
  633 W. 5th Street, FL 26
  Los Angeles, CA 90071