ITMEDIA NewAffiliateOnboardingCompliancePackage v2

NEW AFFILIATE ONBOARDING
COMPLIANCE PACKAGE
[Last updated August 16, 2019]
ITMEDIA NEW AFFILIATE ONBOARDING COMPLIANCE PACKAGE
TABLE OF CONTENTS
INTRODUCTION ........................................................................................................................................... 2
NEW AFFILIATE COMPLIANCE REVIEW ....................................................................................................... 3
Online Lenders Alliance ........................................................................................................................... 6
RELEVANT LAWS.......................................................................................................................................... 8
CAN-SPAM Act ......................................................................................................................................... 8
.Com Disclosures ...................................................................................................................................... 8
E-Sign Act ................................................................................................................................................. 9
Gramm-Leach-Bliley Act .......................................................................................................................... 9
Telemarketing Sales Rule ....................................................................................................................... 10
Telephone Consumer Protection Act ..................................................................................................... 10
Truth in Lending Act ............................................................................................................................... 11
Unfair, Deceptive, or Abusive Practices Act ........................................................................................... 11
PROHIBITED TERMS AND PHRASES .......................................................................................................... 13
COMPLIANCE MONITORING ..................................................................................................................... 15
1
INTRODUCTION
The purpose of the ITMEDIA (“Company”) New Affiliate Onboarding Compliance Package
is to assist new affiliates in adhering to all applicable laws and regulations, including the Online
Lenders Alliance (“OLA”) Best Practices when working with Company. The contents in this
package discusses the Company’s new affiliate compliance review process that all affiliates must
go through before working with Company, the important compliance laws in our heavily
regulated industry that our affiliates must follow, terms and phrases that an affiliate is prohibited
from using when advertising to consumers, and how Company will conduct compliance
monitoring on its affiliates. You can reach out to your affiliate manager should you have any
questions in regard to any topic in this New Affiliate Onboard Compliance Package.
Please note that the materials in this New Affiliate Onboarding Compliance Package are
for informational purposes only, and not for the purpose of providing legal advice. You should
contact your attorney to obtain advice with respect to any particular issue or problem.
2
NEW AFFILIATE COMPLIANCE REVIEW
Before Company can start working with a new affiliate, Company will assign a Compliance
Officer to conduct a comprehensive compliance review on the affiliate. Once the review is
completed, the Compliance Officer will make one of three recommendations to Company: (1)
The affiliate is in compliance with all applicable laws, therefore Company can start working with
the affiliate; (2) The affiliate is not in compliance with all applicable laws, but will give the affiliate
time to cure the deficiencies before Company can start working with the affiliate; or (3) The
affiliate is not in compliance with all applicable laws, and recommends Company to not work with
the affiliate since the deficiencies found are so great that even curing it may still harm Company.
Affiliates will be required to complete and submit the following documents to Company:
• Affiliate Agreement
• Insertion Order (IO)
• Affiliate Compliance Questionnaire
• Affiliate’s Form W-9 or W-8
• Affiliate’s Banking Information for Payments
To conduct an adequate due diligence review of a potential affiliate, Company conducts
the following affiliate selection due diligence (as is appropriate for the subject affiliate):
• Confirm that the affiliate holds current and appropriate licenses and bonds.
• Confirm that the affiliate has adequate security measures in place to protect consumer
information at rest, in transit, and from a data breach.
• Confirm that lead data traffic is from consumers located in the United States.
• Review the affiliate’s websites and any creatives.
• Confirm industry knowledge and experience of key professionals.
• Require representations and warranties that the affiliate does business in compliance with all
laws. Seek indemnifications for any future breaches of those representations.
• Require affiliate to disclose any past or present legal actions or investigations.
• Confirm the types of products or services the affiliate offers.
• Ask the affiliate to fill out a questionnaire that identifies key compliance issues – licenses,
bonds, experience, staffing, complaints, enforcement actions by regulators, outstanding
litigation, audits, etc.
• Review the affiliate’s policies, practices, training manuals, and scripting.
• Review the affiliate’s complaint handling procedures.
• Ask for references and recommendations.
• Ask for professional accreditations and memberships.
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Depending on the affiliate campaign(s), the Compliance Officer will review the following
areas in order to ensure compliance:
Website used for POST
• Fully Secured Website and Forces HTTPS

• Privacy Policy Page
o Explains what type of information is collected, as well as how it is shared, used, and
protected
• Terms and Conditions Page
o Is a set of rules which users must agree to follow in order to use a service
• E-SIGN Consent Page
o Consumer must (1) agree to conduct transactions electronically, and (2) be given an
option to opt-out of conducting transactions electronically
• Contact information
o Mailing address, telephone number, email address, or online contact form.
• The website is properly functions on mobile devices
• No prohibited terms or phrases (please see page 13)
• No false or misleading statements that would violate UDAAP (Unfair, Deceptive, or Abusive
Acts or Practices)
• Disclosure that is compliant with the Truth in Lending Act (TILA) when a trigger term is present
• Disclosure near the call-to-action that states, i.e. “By clicking on “Submit”, you indicate that
you have read and agree to the Privacy Policy, Terms & Conditions, and E-Consent”
o The terms “Privacy Policy, Terms & Conditions, and E-Consent” must be linked to the
appropriate webpages
• Website displays proper disclosures
o I.e: “(Website Name) is not a lender or broker and is not affiliated with any lenders or
brokers. (Website Name) does not make lending or credit decisions. This website does
not constitute an offer or solicitation to lend. The form on the website is not an
application for a loan. Loan terms will vary. Loan availability will vary by state.
Approval is not guaranteed. Third-party provider may conduct credit checks related
to the user’s request. (Website Name) will share PII with third-parties for the purpose
of connecting consumers with lenders. (Website Name) is compensated for
connecting consumers with lenders. Late payments of loans may result in additional
fees or collection activities, or both. Each Lender has its own terms and conditions.
Please familiarize yourself with your Lender’s policies for further information. Non-
payment of your loan could result in collection activities. Each Lender has its own
terms and conditions. Please familiarize yourself with your Lender’s policies for
further information. Every Lender has its own renewal policy, which likely differs from
Lender to Lender. Please review your particular Lender’s renewal policy.”
4
Website used for Banners, Link-Outs, and Advertisements
• The content shown on the website is appropriate for ad placement. Some examples of
inappropriate websites include but not limited to offensive, pornographic, political, and
websites tailored to minors.
Acts or Practices)
• If the affiliate is using their own creative, then the creative (content and images) must be
approved by the Compliance Officer
Website used for Emails
• The content shown on the website is appropriate for email campaign. Some examples of
websites tailored to minors.
• Sufficient opt-in language near the call-to-action
o Consumer agrees to receive marketing materials from partners via email
• Adequate privacy policy and/or disclaimers
o Stating that consumer’s information will be shared with partners for the purpose of
sending consumer marketing materials via email
• A way for consumers to unsubscribe their email address
Acts or Practices)
• Emails sent must comply with the CAN-SPAM Act
• Affiliate agrees to our email publishing guidelines
• Affiliate uses our suppression list
• Affiliate uses Company’s unsubscribe links
Website used for SMS
• The content shown on the website is appropriate for SMS campaign. Some examples of
websites tailored to minors
• Adequate privacy policy and/or disclaimers
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o Stating that consumer’s information will be shared with partners for the purpose of
sending consumer marketing materials via SMS
• Proper disclosure next to the call-to-action
o i.e.: I agree and consent to receiving marketing SMS on the phone number provided.
I understand that consent is not a condition to use the service.
• A way for consumers to unsubscribe their telephone number
Acts or Practices)
• SMS campaign and creatives must be compliant with the Telephone Consumer Protection Act
(TCPA)
• SMS creatives must be approved by the Compliance Officer
o Please note that the consumer’s prior express written consent was obtained by the
affiliate, therefore the SMS creatives used must not imply that it is from the Company
Mobile Apps
• The content shown on the mobile app is appropriate for ad placement. Some examples of
inappropriate mobile apps include but not limited to offensive, pornographic, political, and
mobile apps tailored to minors.
• Terms and Conditions
• Adequate privacy policy and data security
Acts or Practices)
It is important that Company has your most up-to-date business information. The duty
falls on the affiliate to notify the Company of any changes to the affiliate’s information, including
but not limited to billing, contact information, and websites.
Online Lenders Alliance

The Online Lenders Alliance (OLA) sets industry standards and best practices by which
OLA members operate, ensuring that consumers are fully informed and fairly treated. Also, the
OLA serves as a resource to federal and state policymakers on issues related to access to credit.
In addition, the OLA informs borrowers about online lending, and provides resources including a
consumer hotline, a portal to report fraud and consumer tips. Company fully adheres to the OLA
industry Best Practices, and Company expects the same from all affiliates. The Company highly
6
recommends the affiliate to read the OLA Best Practices. The Best Practices can be found at this
link: http://onlinelendersalliance.org/best-practices/
7
RELEVANT LAWS
This section provides brief summaries of some of the most prominent laws and
regulations that apply to Company and its Affiliates. These summaries are intended to provide
affiliates with a better understanding of how these rules apply to their day-to-day business
practices. It is the affiliate’s responsibility to fully comply with these standards. Please contact
your affiliate manager if you have any questions in regard to complying with these laws.
CAN-SPAM Act
The CAN-SPAM Act is intended to control “spam” emails. The act regulates all commercial
email messages, meaning that it applies to all of the affiliate’s email campaigns. A single email in
violation of CAN-SPAM can result in fines of over $40,000, meaning that even one small violation
in an email creative could result in millions of dollars in fines when that email is sent to numerous
consumers. As such, it is imperative that Company ensures that all affiliate email campaigns are
fully comply with CAN-SPAM by adhering to the following:
• The “From,” “To,” “Reply-To,” and routing information – including the originating domain
name and email address – must be accurate and identify the person or business who initiated
the message
• The subject line must accurately reflect the content of the message
• You must state that the email is an advertisement
• You must include your valid physical postal address
• You must include an unsubscribe link
• The unsubscribe link on the email must be valid for at least 30 days after the email is sent
• You must honor a recipient’s unsubscribe request within 10 business days
• You must monitor and ensure compliance of the affiliates that are sending emails on your
behalf
.Com Disclosures
The .Com Disclosures are guidelines set forth by the Federal Trade Commission (FTC) to
apply existing consumer prohibition on “unfair or deceptive acts or practices” to online
advertising and sales. The disclosures must be clear and conspicuous. Affiliates can comply with
the .Com Disclosures by:
• Placing disclosures as close to the triggering claim.

• Making sure contents and disclosures are visibly clear and easily readable on all electronic
devices. For example, computers, tablets, smartphones, etc.
• Incorporating disclosures into the ad whenever possible.
8
• Making sure the hyperlink that leads to a disclosure is properly labeled, easily visible, placed
as close as possible to the relevant information, and takes consumers directly to the
disclosure.
• Displaying disclosures before consumers make a decision to buy. For example, before the
“add to shopping cart.” Disclosures may have to be repeated before purchase to ensure that
the disclosures are adequately presented to consumers.
• Repeat disclosures, as needed, on lengthy websites and in connection with repeated claims.
• Use plain language and syntax so that consumers understand the disclosures.
E-Sign Act
The E-Sign Act provides a general rule of validity for electronic records and signatures for
transaction in or affecting interstate or foreign commerce. The E-Sign Act allows the use of
electronic records to satisfy any statute, regulation, or rule of law requiring that such information
be provided in writing, if the consumer has affirmatively consented to such use and has not
withdrawn such consent. To be compliant with the E-Sign Act, affiliates must do the following:
• Include a disclosure on the affiliate’s website that informs the consumer:

o That, by assenting to the company’s terms, the consumer is giving affirmative consent
to conduct transactions using electronic signatures, electronic disclosures, electronic
records, and electronic contract documents.
o Of their right to receive paper or non-electronic records, as well as the right to
withdraw their consent to electronic signatures in future transactions.
• The affiliate is required to maintain electronic records accurately reflecting the information
contained in applicable contracts, notices, or disclosures and that the remain accessible to all
persons who are legally entitled to access for the period required by law in a form that is
capable of being accurately reproduced for later reference.
Gramm-Leach-Bliley Act
The Gramm-Leach-Bliley Act requires that companies who offer financial products and/or
services take adequate steps to protect sensitive consumer data, and provide consumers with
explanations regarding how their data is used, shared, and protected. In practice, this means that
companies must utilize data encryption and other security protocols when dealing with consumer
information. It also means that companies must have adequate Privacy Policies that the
consumer can access to learn about how their information is handled. In order to comply with
the Gramm-Leach-Bliley Act, all affiliates must:
• Make sure that websites have current security certificates and use encryption to protect data
submitted by consumers.
• Make sure that there is a privacy policy that discloses how the company handles consumer
information.
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o Policies must state what type of information is collected.

o Policies must state who the information is shared with.
o Policies must state how the information is used.
o Policies must state how the information is protected.
• Give consumers the option to opt-out of having their information shared with affiliates and
third parties.
o Privacy policies should make it clear to the consumer that they have this right, and
offer an easy way for the consumer to exercise it.
Telemarketing Sales Rule

The Telemarketing Sales Rule (“TSR”) established the National Do-Not-Call Registry
(https://www.donotcall.gov/) and prohibits deceptive and abusive telemarketing practices. The
civil penalty for each violation of the TSR is $40,654. Some key provisions in the TSR includes:
• Call times are restricted to the hours between 8:00am to 9:00pm (the caller’s time zone).
o Please note that some states have stricter call hours.
• When making an outbound call, the telemarketer must disclose (1) the business name, (2)
that the purpose of the call is to sell goods or services, and (3) the nature of the goods or
services being offered.
• The telemarketer must disclose (1) the total costs for the service, (2) any restrictions,
limitations, or conditions for the service, (3) any policies of refunds, cancellations, exchanges,
or repurchases, and (4) if it includes a negative option feature. Negative option feature means
that the consumer will be charged if they do not act to avoid the charge.
• The telemarketer must not threaten, intimidate, or use profane or obscene language.
Telephone Consumer Protection Act

Do not engage in any text messaging or automated phone calls unless Company
authorizes you to in writing and conducts a thorough compliance review of your practices. The
TCPA prohibits unsolicited automated calls and text messages to wireless devices. In practice,
this means that that automated calls/texts may only be sent to consumers who have given prior
express consent to receive such communications. A single accidental call or text in violation of
the TCPA can result in over $500 worth of fines, and a single call or text that is willfully or
knowingly sent in violation of the TCPA can result in over $1,500 in fines. An entire campaign that
is sent without express consent can therefore easily result in hundreds of thousands of dollars or
more in fines. As such, any affiliate that wishes to advertise by sending automated calls and/or
texts must obtain TCPA consent by doing the following:
• Give the consumer the option to opt-in to automated calls/texts.
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o No automated calls/texts may be made to a consumer unless they have expressly

opted in.
• Provide a clear and conspicuous disclosure that consent to these calls/texts is not a condition
of purchase.
o Make sure the consumer has the ability to continue on without opting in to calls/texts.
• Provide a clear and conspicuous disclosure that by opting-in, the consumer will receive future
automated calls/texts at the number the consumer has provided.
o It is best practice to require the consumer to enter their phone number again in a field
next to this disclaimer.
Truth in Lending Act

The Truth in Lending Act, implemented by Regulation Z, applies to lenders and creditors.
Its terms regulate various types of credit, including installment loans. The act requires that certain
disclosures be made to consumers any time that a “trigger term” is used in an advertisement.
These trigger terms include the amount or percentage of any down payment, the number of
payments or period of repayment, the amount of any payment, and the amount of any finance
charge. If an affiliate wishes to include any of these financial terms in their advertisements, they
must do the following:
• Accurately disclose the amount or percentage of any down payment

• Provide the terms of repayment
• Provide the APR using that term of payment
• Make sure to disclose if the rate can be increased later
Unfair, Deceptive, or Abusive Practices Act

The Unfair, Deceptive, or Abusive Practices Act (“UDAAP”) broadly prohibits companies
from engaging in any type of conduct that is unfair, deceptive, or abusive. Under this law, an act
or practice is considered unfair if it causes (or is likely to cause) a substantial injury to the
consumer, deceptive if it misleads (or is likely to mislead) the consumer in any material way, and
abusive if it either interferes with a consumer’s ability to understand a term or condition of a
financial product or takes unreasonable advantage of the consumer’s lack of understanding of
the costs, risks, and/or conditions of the product or service. Adherence to the following
guidelines will help to ensure that affiliate campaigns do not violate UDAAP standards:
• Make sure that advertisements clearly state all the material terms and conditions of the
product/service.
• Make sure that all disclaimers are clear and conspicuous.
o Do not attempt to hide important information in disclaimers.
o Do not use headers or ad copy that contradict the information in the disclaimers.
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• Do not omit information about terms and/or conditions that are important to the consumer’s
decision making process.
• Only advertise products and services that are actually available.
o Do not advertise lower interest rates, or higher loan amounts, than the consumer can
actually obtain.
• Don’t mislead the consumer by using “bait-and-switch” or similar techniques.
o The consumer should fully understand what they are being offered and/or why they
are providing their personal information.
• Even if a claim is literally true, it still may be “misleading.” If so, the claim cannot be used.
• Claims that are not false or misleading may still be abusive. You cannot take advantage of a
consumer lack of knowledge of a product or service, or of their inability to understand risks
involved with a product or service.
• Make it clear who you are and do not misrepresent your role. For example, you cannot make
it appear that you are a lender or that you are not getting compensated for your role.
12
PROHIBITED TERMS AND PHRASES
Shown below is a guide to the types of terminology to avoid in advertisements. These

are words or phrases that a consumer may interpret as unfair, deceptive, or abusive.
• Match you to the: best lenders, best loans, best rates, lowest fee, lowest rate
o These phrases are considered Unfair, Deceptive, or Abusive because we use the ping
tree to connect consumers to the first lender that is willing to offer them a loan, so
the consumer may not be receiving the loan offer they are requesting for or the best
loan offer out there
o Alternative phrase: Connect you to a lender that can work for you
• No credit check
o This phrase is considered Unfair, Deceptive, or Abusive because some lenders perform
a credit check even if they are not using one of the three major credit reporting
agencies
o A soft pull is considered a credit check
• Bad credit ok / No credit ok
o This phrase is considered Unfair, Deceptive, or Abusive because it leads consumers to
believe that anyone with bad credit or no credit will get a loan
o Alternative phrase: All credit types welcome
• No faxing
o This phrase is considered Unfair, Deceptive, or Abusive because some lenders may ask
consumers to fax additional information or paperwork to them
• You will be approved, you will get a loan, 100% approval, guaranteed approval, instant
approval
o These phrases are considered Unfair, Deceptive, or Abusive because it leads
consumers to believe that anyone who submits a loan request will get a loan
o Alternative phrase: You may qualify for a loan
• You are pre-qualified, you are pre-approved
o These phrases are considered Unfair, Deceptive, or Abusive because the consumer
has not submitted their loan request, therefore there is no way for the affiliate to
know that they are pre-qualified or pre-approved
o Alternative phrase: See if you qualify for a loan
• Get your cash immediately, get cash now
o These phrases are considered Unfair, Deceptive, or Abusive because many lenders are
unable to send funds to the consumer’s checking account now, immediately, or on
the same day, especially if it is after the bank’s cut-off time, on a Sunday, or on a bank
holiday
o Alternative phrase: Get your funds as early as the next business day
• Your information is 100% secured
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o This phrase is considered Unfair, Deceptive, or Abusive because no website is 100%

secure, any and all websites are prone to hacking
o Alternative phrase: We keep your data safe and secure, we use data encryption to
protect your information when you submit your loan request on our website
• Flexible payment plans
o These phrases are considered Unfair, Deceptive, or Abusive because the loan offer a
consumer receive from a lender does not have a flexible payment plan
o Alternative phrase: Connect you to a lender that may have a loan that can work for
you
• Apply now, submit your application
o These phrases are considered Unfair, Deceptive, or Abusive because the affiliate is not
a lender. The consumer is not applying for a loan or filling out a loan application on
the affiliate’s website
o Alternative phrases: Submit your loan request, complete the online form
• Search multiple lenders, you will get multiple loan offers
o This phrase is considered Unfair, Deceptive, or Abusive because we use a ping tree
where the consumer is connected to one lender with one loan offer
o Alternative phrase: You may be connected to a lender in our network
• Match
o This phrase is considered Unfair, Deceptive, or Abusive because it leads the consumer
to believe that the affiliate reviewed the consumer’s information and send them to a
lender that gives them the best loan out there
o Alternative phrase: Connect
• We have 100+ lenders
o This phrase is considered Unfair, Deceptive, or Abusive because many affiliates do not
have 100+ lenders in their network, and there is no way for an affiliate to confirm this
number
o Alternative phrase: We have a large lender network
14
COMPLIANCE MONITORING
Company monitors its affiliates to ensure that their relevant policies, processes and
practices (including marketing, origination, collections and processing) comply with applicable
laws, regulations, and industry guidelines and best practices. Company reserves the right to
terminate relationships with those who fail to do so, immediately and in its sole discretion.
All affiliates are required to agree to and comply with Company’s compliance monitoring,
in an appropriate form, manner, and frequency based on the affiliate’s services and relationship
with Company. Company will monitor compliance on all its affiliates by (1) manually reviewing
the affiliate’s websites and marketing materials; (2) using a web crawler to automatically search
for noncompliant terms and phrases on affiliate’s websites; and (3) any other methods deemed
appropriate by Company.
In addition to monitoring affiliates for noncompliant words, phrases, disclosures, etc.,
mentioned in the previous sections in this New Affiliate Onboard Compliance Package, Company
will also monitor affiliates for the following:
• Use of Fraudulent Data. Examples of use of fraudulent data includes:

o Use of consumer information that the affiliate has no right to have;
o Physically entering consumer information into a loan request form without consent
from the consumer;
o Enter fake consumer information into the loan request form;
o Send lead data through Company’s system numerous times in order to create multiple
sales.
• Incentivized Traffic. Incentivized traffic is when an affiliate pays a person in exchange for their
lead information.
• Improper Search Engine Optimization (“SEO”) practices. Improper SEO practices is the use of
deceptive content or use of materials that are in violation of Intellectual Properties laws in
order to boost SEO.
• Use of Malware. A malware is a software that is intended to damage or disable computers
and computer systems.
• Infringement of Intellectual Properties (“IP”). Infringement of IP is the use of copyright,
trademark, or patent materials that is not registered by the affiliate. This shall include using
non-registered IP content or images not belonging to the affiliate, unless consent was given
by the owner.
• Anticompetitive Practices. Anticompetitive practices are defined as unfair business practices
that are likely to reduce competition and lead to higher prices, reduced quality or level of
services, or less innovation. Examples of this includes disrupting third party websites, or
manipulating content.
15
• Cookie Stuffing. Cookie stuffing is where an affiliate manipulates website analytics or

otherwise confusing tracking methods in order to cause affiliate merchants’ tracking systems
to conclude that a user has clicked through a tracking link even if the user has not actually
clicked through any such link.
• Domain Squatting. Domain squatting, or Cybersquatting, is where an affiliate purchases
domain names that use the names of existing businesses with the intent to sell the domain
names for a profit to those businesses.
• Display misleading Blogs and Articles, or fake Consumer Testimonials.
o If an affiliate has blogs and articles on their website, then the affiliate must make sure
that (1) the information displayed is true and not misleading; (2) the blog and articles
are written by the affiliate, not copied and pasted from another source; and (3) state
that the information should not be construed as legal advice.
o If an affiliate has consumer testimonials on their website, then the affiliate must make
sure that (1) the testimonial is from a real consumer that used their services; (2) the
consumer was not paid to give the testimonial, if the consumer was compensated in
any way, then you must disclose it; (3) the photo displayed is from the consumer
giving the testimonial; and (4) state that these results are not typical.
• Consumer Complaints. Company will review and record any and all consumer complaints
against the affiliate. Depending on the situation, either Company or affiliate will reach out to
the consumer in order to resolve the complaint swiftly and amicably. Company reserves the
right to forward any consumer complaints to the OLA.
• Company may also monitor affiliate in other areas not listed in this New Affiliate Onboard
Compliance Package for noncompliance.
Company may open an investigation on an affiliate if evidence of noncompliance is
discovered. During this time, Company may reach out to the affiliate to request information
pertaining to the investigation. It is highly recommended that the affiliate responds to Company’s
request promptly. If an affiliate has been found to be noncompliant, then, depending on the
severity of the noncompliance, Company may take one of the following actions:
• Written Warning. Company will issue a written warning to the affiliate. The written warning
shall state the nature of the noncompliance, and demand that the affiliate cures the
noncompliance within a specific timeframe. In addition, the affiliate must take steps to
making certain that the noncompliance will not happen again.
• Suspension. Company may suspend the relationship with an affiliate when the affiliate (1) has
one or more Written Warnings, (2) the noncompliance is severe enough to warrant a
suspension, or (3) is not cooperating with Company’s investigation or requests. The Company
may give the affiliate a specific timeframe to cure the noncompliance, and take steps to make
certain that the noncompliance will not happen again. Lifting the affiliate’s suspension is at
the discretion of Company.
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• Termination. Company may terminate the relationship with an affiliate when the affiliate (1)
has one or more Written Warnings, (2) has been suspended at least once, (3) the
noncompliance is severe enough to warrant the termination, or (4) is not cooperating with
Company’s investigation or requests. Once the relationship between Company and the
affiliate has been terminated, there will be no opportunity for reinstatement.
17

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NEW AFFILIATE ONBOARDING

NEW AFFILIATE COMPLIANCE REVIEW

• Fully Secured Website and Forces HTTPS

Website used for Banners, Link-Outs, and Advertisements

Website used for Emails

Website used for SMS

Online Lenders Alliance

• Placing disclosures as close to the triggering claim.

• Include a disclosure on the affiliate’s website that informs the consumer:

o Policies must state what type of information is collected.

Telemarketing Sales Rule

Telephone Consumer Protection Act

• Give the consumer the option to opt-in to automated calls/texts.

o No automated calls/texts may be made to a consumer unless they have expressly

Truth in Lending Act

• Accurately disclose the amount or percentage of any down payment

Unfair, Deceptive, or Abusive Practices Act

PROHIBITED TERMS AND PHRASES

Shown below is a guide to the types of terminology to avoid in advertisements. These

o This phrase is considered Unfair, Deceptive, or Abusive because no website is 100%

• Use of Fraudulent Data. Examples of use of fraudulent data includes:

• Cookie Stuffing. Cookie stuffing is where an affiliate manipulates website analytics or

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