Risk Factors & Requirements

• Influencing a consumer’s decisions could trigger RESPAs definition of a referral for a fee, by:

  • Making a Recommendation or Endorsement of a specific lender or Engine by MoneyLion. (e.g. “Company A is a preferred HELOC lender”)

  • Allowing payouts to determine the rank or order of a lender.

• Lead Performance Based Payouts:

  • If a company is not performing services after the lead is transferred, risk increases with payouts further down the funnel after the lead transfer.

  • Therefore, the greatest risk is a revenue share from the commission of a funded loan. A regulator will view this as a kickback OR payment for services not actually performed.

  • We will avoid rev share due to these regulations and do not include them in any contracts. However, there are other types of CPC/CPL sharing that we may accept.

• NMLS Unique Identifier (NMLS ID):

  1. As required by state and federal regulations, our NMLS ID must be displayed to the consumer on all solicitations and advertisements.

  2. Engine by MoneyLion (Formerly Even Financial) NMLS ID 1475872 must be displayed on all Partner Pages and Embeds when a HELOC is being advertised.

• Triggering Disclosure Requirements:

  • Collecting a full application triggers the requirement for certain loan documents to be disclosed to the consumer within a specified time frame.

  • The following 6 pieces of information constitutes a loan application per the CFPB:

    • Name

    • Income

    • SSN

    • Subject Property Address

    • Requested Loan Amount

    • Estimated Property Value

  • We will leave off one of these items in the application flow to avoid any loan disclosure requirement. For example, income or property value can be left off the form.