COMPLIANCE. IT'S WHAT WE DO.

Introduction

Working with LeadsMarket.com means more than just joining a group of technology experts. It means joining a team focused on innovation, compassion for others and most importantly compliance.

Our commitment to compliance comes from our dedication to our mutual long-term success. On this page:

  1. Compliance is Critical to Success
  2. Our Proactive Compliance Programs; and
  3. How to Get Involved

1. Compliance is Critical to Success

In light of new regulatory developments and increased regulatory scrutiny in the world of consumer finance, compliance is more important than ever. This applies equally to lenders and their key service providers.

LeadsMarket.com's compliance initiatives are based on guidelines, consent orders and lawsuits from the Consumer Financial Protection Bureau (CFPB) and the Federal Trade Commission (FTC) brought against other companies in the consumer finance world. We also look closely at all applicable federal and state rules and regulations to ensure our compliance initiates are comprehensive and current.

Even though proper compliance helps lenders and their service providers, at its heart, compliance is about protecting the consumer.

2. Our Proactive Compliance Programs

Compliance for Publishers: "Be Creative. Be Compassionate. Be Compliant."

LeadsMarket.com encourages publishers to be creative with their marketing strategies but never at the expense of compliance. Publishers must not misrepresent themselves as lenders or brokers, or misrepresent the way consumers are matched with lenders (i.e., we do not allow publishers to suggest a consumer will be matched with "the best" lender or the lender with the "lowest rates"). To help our publishers ensure their marketing strategies are compliant, we implemented several helpful initiatives:

  • Compliance Resources
  • Proprietary CRAWLER
    • Sure, we could buy an off-the-shelf solution, but that's not as reliable, flexible or adaptable as creating our own. So that's what we did. LeadsMarket.com's proprietary CRAWLER is a second layer of compliance protection that helps us closely monitor publisher websites. When the CRAWLER discovers non-compliant keywords and terms, publishers are notified to fix the compliance issues immediately. Websites that are not updated to reflect proper compliance will be suspended or terminated and, depending on the severity of the violations, publishers may be banned from our network.
    • CRAWLER results don't stop at technology (after all, context is a big part of what makes certain words compliant or noncompliant). Our in-house account managers are trained extensively on compliance issues and can help publishers understand why certain words or phrases might not be acceptable and to come up with compliant alternatives.
  • Account Manager Team Support
    • LeadsMarket.com's in-house team of account managers assists publishers with their marketing efforts, from brainstorming ideas, providing templates for sites and banners, or offering real-time analytics
    • Our account managers undergo routine compliance training at least once a month. They also have access to our library of compliance resources, which they are happy to share with you. While LeadsMarket.com and our account managers cannot give you specific legal advice, we can help point you in the right direction and give you our perspective on compliance. Our most popular resources are our one-page guides on how to avoid UDAAP, TCPA and CAN-SPAM violations.
  • Compliance Department Offers Full Support
    • If publishers need more in-depth assistance with compliance, no fear, LeadsMarket.com's Compliance Department can help. Our Compliance Department team members can spend one-on-one time with publishers to help them understand what works within the law and what may result in compliance violations. Contact compliance@leadsmarket.com for more info.

Compliance for Buyers: "Partnering with Compliance is Partnering for Success."

  • Robust Vetting Practices
    • As a technology company, we believe not only in going fast, but also in going far. LeadsMarket.com's vetting practices are designed to promote long-lasting relationships. We can help each other stay out of the federal and state regulatory cross-hairs.
    • Let's be clear. We do not and will not work with just anyone. It's not all about money—it's also about staying power. That's why we strive to work with the good guys and avoid those who disrespect or blatantly ignore compliance concerns.
    • Our vetting practices include a review of each lead-buyer's data security policies and practices to ensure they offer consumers adequate protection. We also want to see business and lending license and make sure our buyers have a working knowledge of applicable lending laws.
    • We also want to be vetted by our buyers. We expect it. We welcome it. It's a sign of good business practices.
  • Online Lenders Alliance (OLA)
    • LeadsMarket.com is the first (by about a year!) technology company to be accredited by the Online Lenders Alliance. Accreditation required a rigorous external audit of our practices, compliance with applicable law and with OLA's Best Practices and Code of Conduct. Accreditation isn't one-and-done either. We conduct internal audits at least
  • Training/Internal Audits/Policy and Procedures Review
    • LeadsMarket.com conducts annual compliance training for all employees. Training covers a wide range of compliance concerns. Trainings are designed to establish a deep understanding of the issues, and ensure employees are up-to-date with applicable laws and regulatory enforcement actions.
    • Training includes sessions on data security, UDAP issues under FTC Act Section 5, UDAAP issues under Dodd-Frank, TCPA, CAN-SPAM Act, Fair Debt Collection Practices Act, Equal Credit Opportunity Act and much more. Our training programs are reviewed during our annual audits. Our Compliance Department also performs quarterly reviews of our internal policies and procedures to ensure accurate and compliant audit results.
  • Consumer Complaints Monitoring
    • We take consumer feedback seriously. LeadsMarket.com has an in-house Consumer Complaints Group designed to investigate, respond to and remediate complaints related to our services. The Consumer Complaints Group prepares a bi-weekly report that helps us understand trends, identify concerns, and minimize overall complaints.

3. How to Get Involved

  • Compliance isn't a box you check. It's a way of life for the business and it is a team effort. Our compliance practices are relevant to every aspect of our business, which is why everyone in the company is involved in compliance training. And everyone is accountable.
  • Whether you are a publisher or a lender, your compliance efforts have significant long-term repercussions to our industry and to our individual business. Promoting a healthy compliance routine is essential to longevity.
  • We should always be on the lookout for bad actors. You know the saying…one bad apple can spoil the entire bunch. If we don't police ourselves and try to keep the bad guys out, eventually we will be defeated by overly burdensome laws and regulations. That doesn't help us, it doesn't help you, and ultimately it hurts the consumer. If you know of bad actors in our industry, please let us know, or report it to OLA, the FTC or the CFPB: