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Compliance

As a financing platform we follow regulations guiding consumer lending practices. One major focus is how we market to our customers. Please review the information below and follow Credova’s Markting Policy.

Important legislation to follow​

Equal Credit Opportunity Act: The ECOA Prohibits creditors discriminating against credit applicants on the basis of race, color, religion, national, origin, sex, martial status, age, because an applicant receives income from a public assistance program, or because an applicant has in good faith excersized any right und the Consumer Credit Protection Act.

Truth In Lending Act: The Truth in Lending Act is a federal law passed to ensure that consumers are treated fairly by businesses in the lending marketplace and are informed about the true cost of credit. The TILA requires lenders to disclose credit terms in an easily understood manner so that consumers can confidently comparison shop interest rates and conditions.

Unfair, Deceptive, Abusive Acts or Pratices: UDAAP prohibits acts and practices that could cause injury, statements o omissions that are deceptive and misleading where a reasonable consumer would be mislead.

CANSPAM​

  • Don't use false or misleading header information. Your "From", "To", "Reply-To", and routing information — including the originating domain name and email address — must be accurate and identify the person or business who initiated the message.

  • Don't use deceptive subject lines. The subject line must accurately reflect the content of the message.

  • Identify the message as an ad. The law gives you a lot of leeway in how to do this, but you must disclose clearly and conspicuously that your message is an advertisement.

  • Tell recipients where you're located. Your message must include your valid physical postal address. This can be your current street address, a post office box you've registered with the U.S. Postal Service, or a private mailbox you've regis-tered with a commercial mail receiving agency established under Postal Service regulations.

  • Tell recipients how to opt out of receiving future email from you. Your message must include a clear and conspicuous explanation of how the recipient can opt out of getting email from you in the future. Craft the notice in a way that's easy for an ordinary person to recognize, read, and understand. Creative use of type size, color, and location can improve clarity. Give a return email address or another easy Internet-based way to allow people to communicate their choice to you. You may create a menu to allow a recipient to opt out of certain types of messages, but you must include the option to stop all commercial messages from you. Make sure your spam filter doesn't block these opt-out requests.

  • Honor opt-out requests promptly. Any opt-out mechanism you offer must be able to process opt-out requests for at least 30 days after you send your message. You must honor a recipient's opt-out request within 10 business days. You can't charge a fee, require the recipient to give you any personally identifying information beyond an email address, or make the recipient take any step other than sending a reply email or visiting a single page on an Internet website as a condition for honoring an opt-out request. Once people have told you they don't want to receive more messages from you, you can't sell or transfer their email addresses, even in the form of a mailing list. The only exception is that you may transfer the addresses to a company you've hired to help you comply with the CAN-SPAM Act.

  • Monitor what others are doing on your behalf. The law makes clear that even if you hire another company to handle your email marketing, you can't contract away your legal responsibility to comply with the law. Both the company whose product is promoted in the message and the company that actually sends the message may be held legally responsible.

The Credova Marketing Policy​

Throughout this guide, the Credova marketing policy will be noted. In general, please follow these rules when communicating with your customer base regarding Credova

Do not alter or modify marketing copy or materials provided by Credova. This includes emails, images, printed materials, logos and disclaimers.

Please submit any independently created consumer facing marketing copy or materials referencing Credova to the Credova marketing team for review prior to distribution.

Please follow the Credova Disclaimer Trigger policy and display written disclaimers in customer facing materials as provided by Credova.

Marketing Compliance

Please follow all ECOA, TILA, UDAAP and CAN-SPAM guidelines when marketing Credova to your customer base.