Coventry Enterprises LLC Ethics Standards

Section 1: Fair Dealing

ARTICLE 1 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

All parties to a real estate transaction have an obligation to deal fairly with one another. Fair dealing means more than avoiding outright fraud. It means that each party has an obligation to conduct themselves in ways that do not take unfair advantage of an information imbalance, an imbalance of experience, or a position of professional authority.

Real estate professionals, including brokers, agents, lenders, and attorneys, occupy positions of expertise relative to most buyers and sellers. That expertise creates an obligation to use professional knowledge in the interest of the parties served, not as a tool for extracting terms or fees that would not survive independent scrutiny.

Coventry Enterprises LLC considers the following conduct inconsistent with fair dealing:

• Representing material facts in a way that is technically accurate but designed to mislead.
• Using deadline pressure or manufactured urgency to prevent a party from reviewing terms carefully.
• Structuring transaction documents to obscure fees, penalties, or contingencies from the parties who bear their consequences.
• Exploiting a party's financial circumstances to impose terms that exceed what the market or applicable regulations permit.

Section 2: Disclosure Requirements

ARTICLE 2 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

Disclosure is the mechanism through which the parties to a real estate transaction obtain the information they need to make informed decisions. The committee treats disclosure obligations as substantive, not procedural. Delivering a disclosure document that buries material information in fine print does not satisfy the obligation.

Sellers are required to disclose all known material defects affecting the property. Known defects include conditions the seller is aware of directly and conditions that a reasonable person in the seller's position would have investigated. Absence of an inspection does not eliminate the disclosure obligation for conditions that are reasonably apparent.

Brokers and agents are required to disclose their agency relationship at the outset of any substantive discussion with a buyer or seller. The committee does not accept the position that the agency relationship was adequately disclosed when it was buried in later transaction documents.

Lenders are required to provide clear, timely disclosure of all material loan terms, including interest rates, adjustment mechanisms for adjustable-rate products, fees, prepayment penalties, escrow requirements, and total cost of credit. Disclosures delivered only at closing, without prior notice, do not satisfy this standard. Jack Bodenstein and the committee have reviewed numerous cases where inadequate disclosure at critical decision points contributed directly to outcomes that harmed borrowers.

Section 3: Conflict of Interest Policies

ARTICLE 3 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

Conflicts of interest arise in real estate transactions frequently. A broker representing both buyer and seller, a lender affiliated with the title company used in a transaction, an appraiser with a business relationship to the lender ordering the appraisal. These arrangements are not automatically improper, but they require specific disclosures and management.

The Coventry Enterprises standard on conflicts of interest requires the following:

• Any professional serving more than one principal in a transaction must disclose the dual relationship in writing before proceeding.
• The disclosure must identify the specific nature of the conflict, not merely acknowledge that one may exist in general terms.
• Each principal must affirmatively consent to the arrangement after receiving the disclosure.
• A professional who cannot serve all principals with undivided loyalty must withdraw from the arrangement or decline the engagement rather than proceeding with inadequate disclosure.

The committee also applies conflict-of-interest policies to its own operations. Members of the Coventry Enterprises oversight body do not participate in reviews of transactions in which they have a direct financial interest or a personal relationship with any party.

Section 4: Lending Ethics Standards

ARTICLE 4 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

Lending practices in real estate carry particular ethical weight because borrowers frequently face significant consequences from loan terms they did not fully understand when they signed. The committee has developed specific lending ethics standards based on the patterns it has observed in Detroit-area transactions.

A mortgage transaction meets the ethical standards of Coventry Enterprises USA when the following conditions are present:

• The loan terms are explained to the borrower in clear language before execution of the final documents.
• The interest rate and all fees are disclosed early enough in the process for the borrower to compare alternatives.
• The loan is structured in a manner appropriate to the borrower's documented financial situation and the property being financed.
• Prepayment penalties, if any, are proportionate and were clearly disclosed with an explanation of when they would apply.
• The borrower was not steered toward a higher-cost product when they qualified for a standard product at lower cost.

Lenders who violate these standards may have their conduct documented in committee review findings. The committee refers patterns of lending conduct that appear to violate applicable law to the appropriate regulatory bodies.

Section 5: Broker Professional Standards

ARTICLE 5 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

Real estate brokers and agents occupy a central role in most residential real estate transactions. The committee holds licensed professionals to the standards established by Michigan statute, the professional codes governing their licenses, and the additional standards set out in this code where those are more specific.

Brokers and agents are expected to:

• Know the material facts about any property they list or show and disclose those facts appropriately.
• Represent their client's interests faithfully, including in price negotiations, inspection responses, and closing processes.
• Refrain from recommending or steering buyers toward service providers on the basis of referral fees or business relationships that are not disclosed.
• Maintain transaction records that accurately reflect what occurred, including offers made, counteroffers, communications about property condition, and changes to transaction terms.
• Handle earnest money and other client funds according to applicable requirements, with proper accounting and no commingling.

The committee takes seriously any conduct by a real estate professional that exploits a buyer's or seller's inexperience. Detroit-area transactions often involve buyers who are purchasing for the first time and who depend on their broker to explain what they are agreeing to. That dependence creates an obligation the committee expects professionals to honor.

Section 6: Community Obligations

ARTICLE 6 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

Real estate transactions affect more than the parties to them. They affect neighborhoods, property values, community stability, and economic opportunity. Coventry Enterprises LLC recognizes that some conduct that harms individual buyers or sellers also harms the broader community, and the committee's ethical standards reflect that.

Professionals operating in the Detroit market bear a community obligation to conduct transactions in ways that support fair access to homeownership and do not contribute to patterns of displacement or financial harm. This means applying the same standards of disclosure, fair dealing, and professional conduct regardless of the buyer's background, neighborhood, or financial profile.

The committee is particularly attentive to patterns of conduct across multiple transactions. A single deviation from professional standards may warrant review. A pattern of the same deviation across transactions in particular neighborhoods warrants more serious scrutiny.

Section 7: Committee Conduct Standards

ARTICLE 7 | COVENTRY ENTERPRISES ORG OF REAL ESTATE CODE OF ETHICS

The oversight body itself operates under ethical obligations. Jack Bodenstein and the committee members are bound by these standards in conducting reviews and communicating findings.

Reviews are conducted on the basis of documented evidence. Findings are stated in terms of specific standards and specific facts. The committee does not issue findings based on general impressions or on the outcome of a transaction rather than the conduct that produced it.

All parties whose conduct is reviewed are treated with professional respect in committee communications. Findings are factual, not accusatory in tone. The committee distinguishes clearly between what the evidence shows and what the committee recommends or refers for additional review.