Online Lenders Alliance Best Practices

ITMedia Solutions, LLC. (“IT Media”)  adheres to certain practices deemed by the Online Lenders Alliance (OLA) as "Best Practices" by ensuring that all our company websites and affiliate’s websites reflect these compliance principles that are designed to assist consumers better understand the process of taking out a payday loans.

As affiliates of IT Media, we recommend that you follow these practices in order remain compliant with applicable Federal and State laws, rules and regulations.

General Recommendations:

• Refrain from engaging in activities that are unfair, abusive or deceptive.
• Avoid creating the impression that affiliate sites are lenders or operate as lenders. Consumers should be informed that these sites are not lenders and instead provide a referral service to qualified participating lenders.
• Advertisements should be truthful, accurate, and reflective of the service. Never mislead Consumer through false misrepresentations.
• Don’t advertise that you can guarantee a loan, loan amount, or state that 100% of applicants will be approved.
• Refrain from advertising a specific APR %.
• Do not advertise that loans can be taken out with “bad credit” or with “no credit check.”
• Inform Consumers that some lenders do conduct credit checks.
• Representations regarding cash in "one hour" or "same day" should not be made. Only represent time accurately.
•   Do not advertise that loans can be taken out with “bad credit” or with “no credit check.”

Privacy Policy, Terms and Conditions, and Disclosures:

• All sites should have visible "Terms and Conditions," “E-Consent Policies,” and "Privacy policies", and links to these pages on their homepage and every other page of their site.
• Terms and Conditions must address the following subjects: Loan requests acceptance policy, restrictions, FCRA compliance, Intellectual Property, Law and Venue, Indemnification, Violation of Terms of Use, and Contact information. The page must also disclose that application information provided by consumer will be shared with one or more lenders.
• Privacy Policies must clearly address the following topics: How personally identifiable information is collected, with whom it is shared, how it is used, and how it is secured; How your company responds to "do not track" signals; Opt-In and Opt-out procedures; Gramm-Leach-Bliley Act information; Patriot Act information
• In regard to Contact information, websites must include their address and telephone number on contact page, and website owners must be easily identifiable.
• WEBSITES MUST NOT INFRINGE ON THIRD PARTY INTELLECTUAL PROPERTY RIGHTS, INFRINGE ON TRADEMARK WORDS, WORDS TOO SIMILAR TO TRADEMARKED WORDS, OR USE THIRD PARTY COPYRIGHTED CONTENT AND DESIGNS.
• Before Consumers can proceed from the short form to the long form on your homepage, they must check off a box next to the following statement at the bottom of the short form: “By submitting your information, you acknowledge you have read, understand, and agree to the terms of our Privacy Policy, E-Consent, and Terms & Conditions of Use, and consent to your information to be shared with select marketing partners.”

• The terms "Privacy Policy", “E-Consent”, and "Terms & Conditions of Use" in the indented statement above should be hyperlinked to each respective document.

Further recommendations:

• Within a “Rates and Fees” or “Responsible Lending” page, the implications of late payment (i.e., late fees, collection activities) and the consequences of non-payment (i.e., collection activities)
• An explanation of sustained use of loans (ex: renewals, extensions). Included a disclosure, as follows: "Loan renewal policies are largely governed by state legislation. The loan renewal options will be disclosed by your lender prior to your acceptance of the loan.”
• A disclaimer concerning availability, as follows: “Loan availability, terms, and policies vary by lender, state, and applicant qualifications.”