Consent Requirements

Applies to: Personal Loans, Banking (Deposits), and 2nd Look Marketplace Native API integrations.

Does not apply to: Auto Insurance unless its product-specific requirements state otherwise.

Use this reference to collect, present, and retain the consents required before requesting offers. It applies to Personal Loans, Banking (Deposits), and 2nd Look Marketplace integrations.

Present Engine’s consent language exactly as written. Alternative language requires express written approval from Engine.

Requirement chart

Consent or agreement	When it is required	What it must cover
Engine consent language	Required when requesting offers	TCPA opt-in, E-Consent, Terms of Service, Privacy Policy, Financial Privacy Notice, Credit Authorization, periodic consumer-report access, and direction to share information
TCPA consent	Optional opt-in	An unticked affirmative control; marketing calls and texts; automated dialing, artificial or prerecorded voice; opt-out instructions; and no-condition statement
Consent record	Required for E-Consent, Credit Authorization, Terms of Service, and TCPA consent	Date and timestamp, unique user identifier, and the exact displayed consent language

Consumers must agree to all required terms before submitting an offer request. Activate the submission CTA only after collecting the required consents.

Electronic Communications Consent (E-Sign)

E-Sign consent lets consumers receive legally required disclosures electronically. It also permits electronic signatures instead of wet-ink signatures.

Obtain E-Sign consent before requesting offers. Link the consent to Engine’s E-Consent, Terms of Service, Privacy Policy, and Financial Privacy Notice.

1. Hardware and software needed to receive or sign electronic documents.

2. The scope of the consent.

3. How consumers can request paper records.

4. How consumers can withdraw consent.

5. Confirmation that the consumer provided a valid email address.

6. A reminder to update electronic-contact information, including how to update it.

Example language

By clicking “See My Offers”:

• I consent to Engine’s E-Consent, Terms of Service, Privacy Policy, and Financial Privacy Notice.

• I consent to Engine’s Credit Authorization, which authorizes Engine and its marketplace partners to obtain consumer report information about me from consumer reporting agencies for the purpose of providing me with personalized offers for financial products and services.

• I further consent to Engine obtaining consumer report information about me from consumer reporting agencies periodically in the future for the purpose of providing me, from time to time, with personalized offers for financial products and services. To opt out of Engine obtaining your consumer report information in the future, complete and submit the form available here.

• I direct Engine to share my information, other than consumer report information, with its affiliates and marketplace partners to provide me with personalized offers.

Fair Credit Reporting Act (FCRA) consent

Engine by MoneyLion and financial institution providers may perform a soft credit inquiry to generate offers. A soft inquiry does not affect a consumer's credit score.

Obtain affirmative FCRA consent before requesting offers. The consent must authorize Engine and its marketplace partners to obtain consumer-report information for personalized offers.

Include:

1. Authorization for Engine and marketplace partners to obtain consumer-report information.

2. The purpose of providing personalized financial-product and service offers.

3. Periodic future consumer-report access for refreshed personalized offers.

4. The future-access opt-out mechanism.

5. Direction to share non-consumer-report information with affiliates and marketplace partners.

Example language

I consent to Engine’s Credit Authorization, which authorizes Engine and its marketplace partners to obtain consumer report information about me from consumer reporting agencies for the purpose of providing me with personalized offers for financial products and services.

Telephone Consumer Protection Act (TCPA) consent

TCPA consent authorizes financial institution providers to contact consumers about their offer request through regulated channels. These channels include automatic telephone dialing systems, prerecorded or artificial voice messages, and text messages.

TCPA consent is optional. When offered, obtain affirmative consent through an unticked checkbox or equivalent control. Do not require consent to continue.

1. The phone number the consumer provided.

2. Authorization for you and financial institution providers to contact the consumer through the applicable regulated methods.

3. A statement that consent is not required to request offers.

4. The transaction or purpose covered by the consent.

5. Instructions for opting out of these communications.

Example language

By selecting this checkbox, I give consent to receive marketing phone calls and text messages (including Rich Communication Services or other mobile messaging) from ML Enterprise Inc. (“Engine”) and its affiliates and marketplace partners, or any authorized third party calling or texting on behalf of Engine, its affiliate or its marketplace partner at my phone number. I agree that such calls and/or texts may be conducted by automated dialing systems and may involve the use of artificial (including AI-generated) or prerecorded voice messages, even if I registered my number on a Do-Not-Call Registry. I understand that my consent is not required as a condition to purchase products or services. To opt out of calls and texts from Engine, call [phone] or reply STOP. For info, reply HELP. Message and data rates may apply. Message frequency varies. For additional information, please review our Terms of Service and Privacy Policy. Please review terms from Engine’s marketplace partners for information about how to opt out of calls and text messages from them.

Use Jornaya for third-party TCPA consent verification.

Email consent

Obtain opt-in consent before Engine by MoneyLion or financial institution providers email consumers about offers or related services.

The consent must identify:

1. The email address the consumer provided.

2. Authorization to contact the consumer about requested and related products or services.

Example language

By providing your email address, you agree to receive email communications from Fiona.com (powered by Engine by MoneyLion) and its partners, and their affiliated companies, at the email address you provided, regarding the financial products and/or services you inquired about as well as other related financial products and services.

Privacy Policy

Provide a Privacy Policy in the consumer flow. It does not need to be unique to an Engine by MoneyLion integration.

The agreement records the consumer's consent to data collection and sharing with Engine by MoneyLion's financial services partners.

The policy must explain how consumer information is:

1. Collected.

2. Used.

3. Shared.

4. Stored.

Native API partners should collect consent to their own Privacy Policy.

Terms of Service

Maintain Terms of Service for your website. Require consent to Engine’s Terms of Service before the consumer submits an offer request.

Capturing consents

Retain an electronic record of E-Consent, Credit Authorization, Terms of Service, and TCPA consent. Each record must include:

1. Date and timestamp.

2. Unique user identifier.

3. The exact consent language displayed to the consumer.

Placement and call to action

Present the required consent language before the CTA. The consumer must agree to the required agreements before submitting an offer request. TCPA consent must remain optional.