Disclosures

In this section you will find guidance regarding the disclosures that may be applicable to your Native API integration. Unless otherwise indicated, the guidelines in this section are for informational purposes only.

The Disclosures included in this section are applicable to ALL financial products offered on Engine by MoneyLion’s platform. Examples of the disclosures found on Engine by MoneyLion owned experiences can be found in APPENDIX B.

Advertiser Disclosure

The Advertiser Disclosure is REQUIRED by Engine by MoneyLion and must be included on each page of the site where offers are displayed or discussed.

• Guidelines: The Advertiser Disclosure must include the following four elements:

  1. You receive compensation from the companies who provide the offers.

  2. The compensation you receive may influence the selection, appearance, and order of appearance of the offers listed.

  3. The consumer is not charged to receive offers.

  4. The offers shown do not reflect an exhaustive list of available offers or products. \

• Placement: The Advertiser Disclosure must be clear, conspicuous, and prominent. Additionally the Advertiser Disclosure must appear at the top of the page / above the fold. This means the consumer should not have to scroll in order to see the link for the Advertiser Disclosure.

For more information about the requirements for the Advertising Disclosure see 12 CFR 1026.24 Advertising

Annual Percentage Rate (APR) Disclosure

Rates included in offers for financial products must be stated in terms of an annual percentage rate (APR) and should include a disclosure, referred to here as the APR Disclosure, that defines what is included in the APR.

• Guidelines: The APR Disclosure should include the following four elements:

  1. Must include the term “Annual Percentage Rate or APR” and define APR as the measure of the cost of credit.

  2. Must state that the APR is based upon the amount of the loan, the cost of the loan, term of the loan, repayment amounts, timing of payments, and payoff.

  3. Must explain that rates may vary based upon creditworthiness, loan size, and other variables. In addition, maximum and minimum loan amounts and APRs may vary by state law and lender. \

• Placement: The APR Disclosure should be included on the first page where an APR appears. In addition, the APR Disclosure should also be placed at the bottom of every page, or one click away, from the consumer experience.

Representative Example

Additional disclosures are needed when consumers are presented with offers for financial products that contain “trigger terms.” The “trigger terms” are: downpayment, payment period, payment amount, and finance charge. The additional disclosures can be presented to consumers in the form of a Representative Example.

• Guidelines: The Representative Example should contain the following information which is used to provide context to the terms presented in the offer:

  1. Payment period – The number of payments or period of repayment.

  2. Payment amount – The amount of any payment.

  3. Finance charge – The amount of any finance charge.

  4. Down payment – The amount or percentage of any down payment required, if any.\

• Placement: The Representative Example should immediately follow the APR Disclosure. Similar to the APR Disclosure, the Representative Example should also be placed at the bottom of every page, or one click away, from the consumer experience.

General Disclosure

We recommend that you provide a disclosure informing consumers that offers are not guaranteed and subject to change.

• Guidelines: The General Disclosure should include the following four elements:

  1. Offer is based on information provided by the consumer.

  2. All rates, fees, and terms presented are not guaranteed and are subject to change at the discretion of the financial institution.

  3. Offers may not be available in all states or for all types of loans.

  4. No guarantee that the consumer will qualify, or be approved, for the advertised rates, fees, or terms.

Product Specific Disclosures

Some financial products require disclosures that are in addition to the disclosures presented in this section. Please refer to the product specific addendums for information on the product specific disclosures: HELOC Addendum, Savings Addendum.

Offer Disclosure

The Offer Disclosure is REQUIRED and must be displayed on the page where offers for financial products are displayed.

• Guidelines: The Offer Disclosure should include the following three elements:

  1. If the Consumer did not receive an offer or did not receive an offer from a particular financial institution provider (lender), the lender may have been unable to determine if the Consumer qualified for the financial product based on the information provided by the Consumer.

  2. No credit decision has been made.

  3. The Consumer may still qualify for financial products from one of our financial institution partners (lenders).

Licensing Disclosure Recommendation

We recommended that you include “Powered by Engine by MoneyLion (formerly Even Financial, NMLS# 1475872)” in your flow as Engine by MoneyLion maintains the requisite licenses for all business activities conducted on Engine by MoneyLion’s platform.