Policy | Advertising & Marketing Compliance Policy

Created by Roma Caraher, Modified on Thu, 23 Apr at 2:35 PM by Roma Caraher

Advertising and Marketing Compliance Policy

Effective Date (revised): April 6, 2026

Approved by: Robert Bagley

1. Purpose

This policy establishes uniform standards for all advertising and marketing activities related to residential mortgage loans. It ensures full compliance with:

All applicable federal laws and regulations, including the Truth in Lending Act (TILA) and Regulation Z (12 CFR § 1026.24), the Fair Housing Act, the Equal Credit Opportunity Act (ECOA), the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act), Nationwide Multistate Licensing System (NMLS) requirements, and prohibitions on unfair, deceptive, or abusive acts and practices (UDAAP).
The mortgage licensing, advertising, and consumer protection laws of each state in which the Company is licensed (or exempt) to originate residential mortgage loans or in which any advertisement is directed, disseminated, or expected to reach consumers.

The policy prevents unfair, deceptive, or misleading advertising, addresses the recent regulatory citation regarding social media and MLO pages, and ensures the Company can promptly provide all requested marketing materials during state examinations or audits. All materials must be truthful, accurate, non-discriminatory, and compliant with the requirements of every applicable jurisdiction.

2. Scope

This policy applies to all employees, Mortgage Loan Originators (MLOs), agents, contractors, and third parties acting on behalf of the Company. It covers all forms of advertising and marketing used to solicit residential mortgage loans in any state, including but not limited to:

Printed materials (print ads, brochures, direct mailings, flyers, business cards).
Radio or television transcripts/scripts.
Electronic/digital advertisements (websites, email solicitations, online banners).
Telemarketing scripts and oral solicitations by sales staff.
Social media pages, posts, profiles, videos, and content (Facebook, Instagram, X/Twitter, LinkedIn, YouTube, TikTok, etc.) for both the Company and individual MLOs.
Any other promotional materials or communications that mention or imply mortgage products, services, rates, terms, prequalification, or preapproval.

Advertising may only be used or targeted in states where the Company and the relevant MLO(s) are properly licensed or exempt under that state’s laws. This policy applies whether the content is created internally, by MLOs personally, or by external vendors.

3. Responsibilities

Compliance Officer (or designated approver, e.g., Bob): Reviews and approves all advertising and marketing materials before publication, posting, distribution, or broadcast. The Compliance Officer maintains current knowledge of state-specific advertising requirements and ensures they are addressed in the approval process.
MLOs and Staff: Submit all proposed content for pre-approval. Ensure required disclosures are included and visible. Do not post, send, or use unapproved materials.
Operations / Marketing Team: Maintain records of all approved materials and ensure retention requirements are met.
All Personnel: Complete annual training on this policy and report any suspected violations immediately.

Violations may result in disciplinary action, up to and including termination, and may subject the individual and the Company to regulatory penalties in any applicable state or at the federal level.

4. General Advertising Requirements

All advertisements must:

Be truthful, accurate, and not misleading.
Comply with Regulation Z (12 CFR § 1026.24): Use only terms that are actually available; state rates as “Annual Percentage Rate” (APR) when required; provide clear and conspicuous disclosures for triggering terms (e.g., rates, payments, terms).
Avoid prohibited practices under applicable state laws, which commonly include:
- Advertising unqualified access to credit without clearly disclosing all material limitations or conditions.
- Advertising a specific interest rate without stating that the rate is subject to change and may not be available at commitment or closing.
- Advertising loans, rates, fees, or terms unless the Company can make such loans available to a reasonable number of qualified applicants in the state(s) where the advertisement is used.
Not engage in unfair, deceptive, or abusive acts or practices (UDAAP) under federal or state law.
Clearly identify the Company and any applicable DBA (e.g., “Coast2Coast, LLC [DBA Name]” or “Powered by [Coast2Coast, LLC]” or “Subsidiary of [Coast2Coast, LLC]”).

5. Multi-State Compliance Note

The Company is licensed (or exempt) in multiple states through the NMLS. Because advertising requirements can vary by state, all materials must satisfy the specific rules of every state in which the advertisement may reach consumers or in which the Company/MLO is licensed. This includes any additional state-mandated disclosures (e.g., state license numbers, “licensed by the [State] Department of Financial Institutions,” or other jurisdiction-specific language). The Compliance Officer will incorporate current state-specific requirements into the pre-approval process. Where state law is more restrictive than federal requirements, the stricter standard applies.

6. Required Disclosures (Mandatory for All Materials)

Every advertisement, post, page, profile, video, email, business card, website landing page, or solicitation must visibly and conspicuously include:

The MLO’s full name exactly as it appears in NMLS.
MLO’s NMLS ID number.
The Company name (Coast2Coast Mortgage, LLC. If you have a DBA, it must still show ‘DBA or Powered by or Subsidiary of’).
The Company’s NMLS ID number (376205).
The phrase “Equal Housing Lender” or the Equal Housing Lender logo.

Visibility Rules:

Disclosures must appear in the main post text, profile bio, video captions, or on the landing page itself.
They cannot be hidden in comments, “read more” sections, links to another page, or footnotes.
They must be clear, conspicuous, and easily readable (not in fine print or obscured).

For websites and online landing pages, disclosures must be visible without requiring navigation to a separate page.

7. Social Media and Digital Content Requirements

All social media content (posts, pages, videos, profiles, stories, reels, etc.) on any platform must comply with Section 6 above. This includes personal MLO accounts when the content relates to mortgage services, the Company, or implies mortgage expertise.

Required information must be in the visible portion of every post, bio, or caption.
Before posting any new content, submit it to the Compliance Officer (or Bob) for review and approval.
The Company will conduct periodic audits of social media accounts to ensure ongoing compliance with both federal and all applicable state requirements.

8. Preapproval / Prequalification Disclaimer

If any advertisement, post, email, script, or communication uses the words “preapproved,” “prequalified,” or any language that could reasonably lead a consumer to believe they are approved for a mortgage (or implies guaranteed approval), the following disclaimer must appear clearly and conspicuously in the same advertisement:

“This is not a commitment to lend. All loans are subject to credit approval and property appraisal. Programs, rates, terms, and conditions are subject to change without notice. Interest rates and annual percentage rates (APRs) are subject to change based on market conditions and borrower eligibility. Not all applicants will qualify. Terms and conditions apply. We are an equal housing lender. We do not discriminate based on ancestry, race, color, religion, sex, disability, familial status, national origin, or military status.”

(or the Equal Housing Lender logo may be used in place of the equal housing lender text).

9. Additional Prohibited Practices

Misleading use of government references, “fixed” rates where variable, or comparisons that omit material facts (per Reg Z and state law).
Discrimination or any statement that could be interpreted as discriminatory (Fair Housing Act / ECOA).
Use of testimonials or endorsements without proper authorization and disclosures.
Any content that simulates a check, government communication, or official document without clear disclaimers.

10. Mass Email & CRM Distribution Policy

Core Requirement
1. To protect our corporate email deliverability, all mass marketing and bulk communications must be sent through your CRM provider’s servers. Use of our internal Microsoft 365 / corporate mail servers for bulk distribution is strictly prohibited.
Technical Rationale
1. Reputation Protection: Bulk sending via internal servers risks domain blacklisting, which can cause standard business emails to be blocked globally.
2. Dedicated Infrastructure: CRM providers use specialized IP addresses designed for high-volume delivery and compliance with ISP standards.
Operational Rules
1. Bulk Threshold: Any email sent to more than 100 recipients is considered a "mass" transmission and must utilize CRM.
2. No SMTP Relays: Marketing tools may not be integrated with our internal SMTP relay or corporate mail flow.

11. Approval Process

All advertising/marketing materials must be submitted via email to support@coast2coastml.com or Bob@coast2coastml.com with sufficient time for review.
Approval must be documented (e.g., dated approval email or form) and will confirm compliance with both federal rules and the requirements of all affected states.
Only approved versions may be used. Changes require re-approval.

12. Recordkeeping and Examination Readiness

The Company will maintain a complete record of samples of every advertisement (including scripts, posts, emails, etc.) for the period required by applicable federal and state laws, typically no less than two (2) years after the date of publication, broadcast, or posting (or longer if required by a specific state). Records will include:

The final approved version.
Date of approval and distribution.
Platform or medium used.
Identification of the state(s) in which the material was used.

This directly supports examination requests from any state regulatory agency for all marketing materials (printed, broadcast, electronic, social media, business cards, emails, oral scripts, etc.).

13. Training and Monitoring

All relevant staff will receive training on this policy upon hire and annually thereafter. Training will include multi-state compliance considerations.
The Compliance Officer will monitor compliance, including random social media reviews and periodic updates for changes in state law.
The policy will be reviewed and updated as needed to reflect changes in federal or state requirements.

14. Enforcement and Contact

Questions regarding this policy should be directed to the Compliance Officer. Failure to comply may result in regulatory citations, fines, or internal discipline in any applicable jurisdiction.

By following this policy, the Company ensures transparent, compliant marketing that protects consumers and maintains regulatory standing in every state in which it operates.