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REV: 06-11-25 LF 31. Anti-Money Laundering. City is responsible for Office of Foreign Assets Control “OFAC” Screening of borrowers prior to loan origination and for compliance with Anti- Money Laundering program requirements of 31 U.S.C. § 5318(h), or other directives that may relate to the appropriate verification of borrower identity to ensure the prohibition of transactions with certain foreign countries and/or their nationals. City agrees to promptly notify Consultant if it becomes aware of its borrowers being added to the Specially Designated Nationals List during the term of this Agreement. 32. Privacy and Data Security. 32.1 The collection, safeguarding and disclosure of nonpublic personal information of borrowers in connection with the loans to be serviced by Consultant pursuant to this Agreement is subject to privacy protections pursuant to federal and state law, including without limitation, the Gramm-Leach-Bliley Act 15 USC 6801 (“GLB Act”) and the regulations of the Federal Trade Commission enacted in connection with the GLB Act. 32.2 City and Consultant each acknowledge its obligation to comply with all applicable laws in the handling of nonpublic personal information of borrowers, including the GLB Act, and confirms that it adheres to the provisions of the regulations and related guidance under the GLB Act, including issuance of the proper privacy notices to its customers if required, as with the FCRA and FDCPA, and the protection of nonpublic personal information pursuant to the Safeguards Rule (67 Fed. Reg. 36484). Each of the City and Consultant will be responsible for all liability arising as a result of its failure to adhere to the foregoing obligations. 32.3 With respect to the processing of payments by borrowers, Consultant will at all times comply with currently required PCI-DSS standards and cardholder information security standards, including the transition to PCI-DSS 4.0. 32.4 Data Security and Breach 32.4.1 For purposes of this Section 32.4, the following definitions apply: (i) “City Data” means all data provided by City in connection with the services to be provided by Consultant pursuant to this Agreement, including any borrower nonpublic personal information. (ii) “City Identified Contact” means the person or persons designated in writing by the City to receive Security Incident or Data Breach notification. (iii) “Data Breach” means the unauthorized access by a non- authorized person that results in the use, disclosure or theft of City Data. ATTY/AGR.2025.144/AmeriNational Community Services, LLC d/b/a AmeriNat (Page 10 of 31)