A.2.2.1.5 Charitable Donations

A. Example 1. A $10,000 donation given by the MAP Lender to a charity run by the wife of a principal in the Borrower’s entity around the time of a project’s application engagement or closing, would be presumed to create a prohibited IOI. The MAP Lender would have to prove that such an IOI does not exist. B. Example 2 . A MAP Lender donated $5,000 to a charity run by the Borrower 10 years ago. An IOI would likely not be created.

C. Example 3. A Map Lender donates money to a charitable foundation researching health care or seniors aging issues. A Non-profit Borrower has a substantial interest in the foundations and its work. The Lender’s contributions were $2,000 each of the past four years. The Lender intends to continue such donations. Such a contribution would not be a prohibited IOI.

D. Example 4. A MAP Lender donated $100,000 to a museum. The MAP Lender made no prior donations to the museum. The museum is a charitable organization in which a principal of the Borrower or one of their close relations has an active and significant participation as a volunteer, board member or donor. This would be presumed to create a prohibited inducement and a conflict of interest, which the MAP Lender would have to prove does not exist.

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Appendix 2 Quality Control Plans and Identity of Interest A.2.3 MAP Lender Representation and Warranty

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