We Take Our Responsibilities Seriously
We work wholly within the letter of the law, and also within the spirit of providing the best possible service to prospects, publishers, and financial partners. This is why we insist that our publishers fully abide by our compliance guide. Failure to do so will result in rejection of your application for publisher status, or the revocation of your active status if you're found to be not in compliance during one of our routine quality checks.
What's Expected of Publishers
Your account management specialist can give you detailed information on the exact requirements for compliance, but this list is a good start:
- You must describe the implications of late payments—in moderate detail and in clear language—so that prospects will not be confused as to the potential penalties.
- Similarly, you must clearly explain the ramifications of no-payment, again so that prospects are not confused as to what awaits them should they default on a loan.
- Loan renewal policies must be clearly explained so that prospects will not be confused as to the consequences of extending repayment terms.
- Your site must include a detailed code of practice/policy on responsible lending which—at a minimum—lays out disclosures required by the Truth in Lending Act, explains that borrowers have recourse with the Consumer Financial Protection Bureau should they be mistreated by a lender, that all debts are subject to the Fair Debt Collections Act, and that all other State and Federal laws related to loans or consumer lending apply.
- You must disclose the fees involved, including an APR representative of the type of loan(s) for which you offer information.
- A complete set of legitimate contact information—including a physical address—must be made clearly and conspicuously available on your site.
- All disclosures under the applicable laws of the state in which you are located as well as the state the prospect is in, and disclosures under all Federal statutes related to loans or consumer lending, must be detailed on the site in a reasonable attempt to convey the relevant information.
Use Clear, Proper Language
We require all language used on our publisher’s sites be clear and understandable. It must be free of any confusing or misleading wording, structure, and no necessary information should be omitted. There should be no use of misdirection in an attempt to generate leads. Some examples have been provided below:
Claims made must not be misleading in general, either by making misleading statements or by omitting information that leads to a consumer being misled. The following rules must also be observed:
- No reference should be made to “safe” or “secure” loans, since loans have inherent risk.
- Do not refer to loans as “private” or “confidential”. Information is shared with lenders, credit checks are run, etc. It is however acceptable to mention convenience, such as the ability to apply from the privacy of your own home.
- Do not claim that the prospect’s credit score may improve by applying for or obtaining a loan.
- Loans should never be referred to as “cheap” or “inexpensive”. As already stated, a typical APR should be used, and a detailed explanation should be given of what this means for repayment.
- Any reference made to “same day” or “next day” service should include a clear disclaimer indicating that not all loans can be processed that quickly—details as to when loans might be processed that quickly are optional.
- No reference to “cash in hand” should be made, though it is acceptable to use wording which indicates that the money will be transferred to the prospect's bank account.
- Reference to non-emergency needs for loans are to be avoided. This includes not mentioning “vacation/holidays” or “early payday” or anything similar. “Unexpected expenses”, “medical bills”, or “surprise repairs” are more appropriate messages.
- When referring to the potential loan amount, you must make reference to both (1) the needs of the prospect and (2) the qualification criteria of the financial institution.
- If you are directly marketing to specific locales, you must use language specific to that location. For example, if the APR for California is 20% higher than the national average, you cannot use an example of a national average on landing pages targeting prospects in California.
- Similarly, for geographically targeted landing pages, you must comply with all the disclaimers or other wording required by that jurisdiction.
Being Responsible Makes Sense
Not only is it legally and ethically right to follow all of the guidelines we lay out for our publishers, it is good business. Attention to all the little details is what helps make LeadsMarket.com one of the best loan lead generation companies in the industry. By taking these matters seriously, we have built up an excellent reputation with prospects, financial institutions, and our valued publishers.