Compliance Guidelines
Compliance guidelines for native API integrations for Loans/Savings/2nd Look Marketplace
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Compliance guidelines for native API integrations for Loans/Savings/2nd Look Marketplace
Last updated
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In order to receive approval from the Engine Compliance team and Financial Services partners, Native API integrations must include specific items in the information collection process.
Advertiser Disclosures
General Consents
This disclosure must appear above the fold on every page of the consumer experience from collecting information to displaying offers. Here is an example of the Advertiser Disclosure:
Offers that appear are from companies from which Engine by MoneyLion and its partners may receive compensation. This compensation may influence the selection, order and appearance of the presented offers. However, this compensation also facilitates the provision by Engine by MoneyLion of certain services to you at no charge. The offers shown below do not include all financial services companies or all of their available product and service offerings. The third-party products are subject to the provider's terms and conditions and privacy policy, and are not guaranteed by MoneyLion.
Here is an example of how it is represented on Engine’s owned experiences:
FCRA Consent is required for lead PII to be passed to Engine's API.
Other consents are required to be collected from the consumer. We will be making these consents available to pass to the API in future builds.
Consent is typically the last step in the information collection process and the language must be conspicuous and located directly near the Call To Action (“CTA”) button for the user to submit their information. Engine and its Financial Services partners require that the user agrees to the following before submitting their information to receive offers:
Phone Number Field: Engine by MoneyLion’s flow requires consumers to provide their phone number. The consumer’s phone number may be used to verify the identity of the consumer.
Optional TCPA Consent: Engine by MoneyLion does not call or text leads received via API partners using auto dialers without an affirmative “1-to-1” consent for it to do so. Starting on January 27, 2025, the only acceptable means for an API partner to collect consent for Engine by MoneyLion to call or text consumers will be for the API partner to feature an UNTICKED box (or similar structure) such that the consumer must take some affirmative action to indicate that they wish to be contacted specifically by Engine for marketing purposes. The consumer must not be required to tick this box in order to proceed through the flow. Note: You are not required to include this TCPA consent in your flow; this is simply an option for partners who wish to optimize lift. It is acceptable to omit TCPA consent from your consent flows entirely.
Below is an example of a compliant, optional TCPA consent:
𝤿 By selecting this checkbox, I consent for Engine by MoneyLion, a partner of [INSERT API PARTNER NAME], to send text messages to my phone number, including for marketing purposes, regarding financial products and services offered by from ML Enterprise Inc. and its partners and affiliates. I agree that such text messages may be sent by automated dialing systems. I understand that my consent is not required as a condition to purchase products or services. To opt out, call (800) 614-7505 or reply STOP. For info, reply HELP. Message and data rates may apply. Message frequency varies. For additional information, please review the ML Enterprise Inc. SMS Terms and Privacy Policy.
Post-Click Calling by Financial Partners: Our policy is that financial service provider partners may call or text consumers who have clicked into an offer from that provider in accordance with the advice of their legal and compliance teams, but may not call or text “pre-click.”
This agreement represents the user’s consent to conduct transactions using electronic signatures, electronic disclosures, electronic records, and electronic contract documents. An example of Engine’s “E-Sign” agreement can be found here.
Partners building a Native API integration are recommended to have users consent to their own version of “E-Sign” agreements. In cases where this is not possible, please reach out to your assigned contact at Engine.
This agreement represents the user’s consent to allow Engine to use the submitted information r to find financial products and services that would be the best match for the user and allow its financial services partners to make a pre-qualification or other credit decisions. An example of Engine’s Credit Authorization agreement can be found here.
Partners building a Native API integration are recommended to have users consent to their own version of Credit Authorization agreements. In cases where this is not possible, please reach out to your assigned contact at Engine.
This agreement represents the user’s consent to agree to follow the terms and conditions of the partner’s experience. Your users must agree to your terms of service and to Engine's Terms of Service.
This agreement represents the user’s consent to how their data will be collected and shared with Engine’s Financial Services partners. Your users must agree to your privacy policy and to Engine's Privacy Policy.
Here is an example of the full consent language and CTA button on Engine’s owned experiences:
Here is the language for your reference:
By clicking “See my offers”:
I consent to the ML Enterprise Inc. (referred to herein as “Engine by MoneyLion”, whether doing business as Engine by MoneyLion or through the Fiona.com website) E-Consent, Terms of Service, Privacy Policy and Financial Privacy Notice.
I consent to Engine by MoneyLion’s Credit Authorization, which authorizes Engine by MoneyLion and its marketplace partners to obtain consumer report information about me from consumer reporting agencies, now, and periodically in the future, for the purpose of providing me with personalized offers for financial products and services.
I direct Engine by MoneyLion to share my information, including consumer report information, with me and with Engine by MoneyLion affiliates and marketplace partners to provide me with financial recommendations or other offers, which may also include debt relief, credit repair, credit monitoring or other related services.
