Additional Compliance Recommendations & Best Practices

Information collected in some Consumer Information Fields will be used by the Financial Institutions on our platform for purposes that require consent and/or legal disclosures. The following fields are recommended to be provided to consumers at the point where that information is being collected.

APPENDIX A contains examples of these items as presented on Engine by MoneyLion owned experiences.

Phone Number Collection Notice

At the point of collection, provide notice to the consumer explaining the purpose for collecting their phone number. The Phone Number Collection Notice is in support of the Telephone Consumer Protection Act (TCPA) Disclosure and Consent.

• Placement: The Phone Number Collection Notice should be placed near the phone number field as a static field or a pop-up/hover field.

Social Security Number Collection Notice

At the point of collection, provide a notice to the consumer explaining the purpose for collecting their social security number. The Social Security Number Collection Notice is in support of the Fair Credit Reporting Act (FCRA) Disclosure and Consent.

• Placement: The Social Security Number Collection Notice should be placed near the SSN field as a static field or a pop-up/hover field.

Credit Rating Ranges

Engine by MoneyLion will pass the consumer’s credit information to the Financial Institutions in exactly the format it is passed to us. Consumer’s credit information can be passed as either a credit score or credit rating. Regardless of the format used, we recommend that you provide a list of credit ratings and associated numeric ranges for reference.

• Placement: The Credit Rating Ranges should be placed near the credit rating field as a static field or a pop-up/hover field.

Annual Income Defined

At the point of collection, provide a definition for “annual income” and the types of income that can be considered.

• Placement: The annual income definition should be placed near the annual income field as a static field or a pop-up/hover field.