Consents

In this section you will find guidelines and best practices regarding the Consents that are needed from the Consumer in order to generate offers on the Engine by MoneyLion’s platform.

Examples of the Consents found on Engine by MoneyLion owned experiences, can be found in APPENDIX C.

Electronic Communications Consent (“E-Sign”)

As an online marketplace, it is necessary to obtain consent from the consumer to receive all legally required disclosures in electronic form. E-Sign Consent also allows for the use of electronic signatures on documents in place of wet ink signatures. E-Sign Consent is REQUIRED in order to request offers on Engine by MoneyLion’s platform.

• Guidelines: E-Sign Consent should include the following six elements:

  1. A description of the hardware & software required to receive and/or sign documents electronically.

  2. Scope of the consent.

  3. Means of requesting paper records.

  4. Method for withdrawing consent.

  5. Statement that the consumer has provided a valid email address for electronic communications.

  6. Statement reminding consumers to update their electronic communication contact information and the method for doing so.

Fair Credit Reporting Act (FCRA)

Engine by MoneyLion and/or the financial institution providers (lenders) on our platform will need to do a “soft pull” of the consumer’s credit report in order to generate offers. A “soft pull” does not impact a consumer’s credit score. Regardless, “soft pulls” do require authorization from the consumer. You are REQUIRED to obtain affirmative FCRA Consent from consumers before offers can be requested.

The FCRA Consent should cover the following practices related to a consumer’s credit report:

- Viewing: Consent to view information in the consumer’s credit report;

- Using: Consent to use information in the consumer’s credit report; and

- Sharing: Consent to share information in the consumer’s credit report with affiliates for marketing purposes.

• Guidelines: FCRA Consent should include the following five elements:

  1. A statement that the consumer is authorizing you, Engine by MoneyLion, and/or the financial institution providers (lenders) on our platform to obtain information about the consumer from one or more consumer reporting agencies.

  2. A statement explaining the purpose for obtaining information from the consumer’s credit report.

  3. A statement that the information obtained from the consumer’s credit report may be shared with Engine by MoneyLion and/or the financial institution providers (lenders) on our platform.

  4. A statement that the financial institution providers (lenders) may also directly obtain the consumer’s information from one or more consumer reporting agencies.

  5. A statement that the financial institution providers (lenders) may use information from the consumer’s credit report in order to make credit decisions.

Telephone Consumers Protection Act (TCPA)

TCPA Consent is needed so that the financial institutions (lenders) on Engine by MoneyLion’s platform are authorized to contact the consumer about their request for offers for financial products using regulated methods such as automatic telephone dialing system (ATDS), artificial or pre-recorded voice messaging, or text message. You are REQUIRED to obtain affirmative TCPA Consent from consumers before offers can be requested.

• Guidelines: TCPA Consent should include the following five elements:

  1. A statement that consent only applies to the phone number provided by the consumer.

  2. A statement that the consumer is authorizing you, and the financial institution providers on our marketplace, to contact them using an automatic telephone dialing system (ATDS), artificial or pre-recorded voice messaging, or text message.

  3. A statement that consent is not required in order to request offers.

  4. A statement explaining the scope of the consent extends to communications related to the transaction or purpose for which the consumer provided the number.

  5. An opt-out notice explaining how the consumer can opt-out of receiving communications via automatic telephone dialing system (ATDS), artificial or pre-recorded voice messaging, or text message.

Email Consent

You are REQUIRED to obtain consent from consumers for Engine by MoneyLion, and the financial institutions on our platform, to communicate with Consumers via email. Consent should be in the form of an “opt-in” meaning the consumer should have to agree to receive emails.

• Guidelines: Email Consent should include the following elements:

  1. A statement that the consent only applies to the email provided by the consumer.

  2. A statement that the consumer is authorizing Engine by MoneyLion, and the financial institutions on our platform (lenders), to communicate with them via email about offers for products and/or services.

Privacy Policy

You are REQUIRED to have a Privacy Policy. The Privacy Policy does not need to be unique to the Engine by MoneyLion platform integration. This agreement represents the user’s consent to how their data will be collected and shared with Engine by MoneyLion’s Financial Services partners. An example of a Privacy Policy agreement can be found here. Partners building a Native API integration are recommended to have users consent to their own version of Privacy Policy agreements.

• Guidelines: Your Privacy Policy should cover the way consumer’s information will be:

  1. Collected

  2. Used

  3. Shared

  4. Stored

Terms of Service

We recommend that you maintain Terms of Service for your website and incorporate them into the Consents being captured prior to the consumer submitting a request for offers.

Capturing Consents

You must retain an electronic record of E-Sign, FCRA, TCPA, and Email Consents. The consent record must include the following data elements:

• Date and timestamp

• Unique user identifier

• Specific consent language that was present at the time the consumer provides their consent.

Placement

Engine by MoneyLion, and the financial institutions on our platform, require consumers to agree to all terms before submitting their request to receive offers for financial products.

Call to Action (CTA)

Once you have collected the consumer information and obtained the required consents from the consumers, the CTA button can be activated. This button is used to submit the request for offers for financial products through the Engine by MoneyLion platform.