1. ActiveComply User Guide

Account & Content Creation

Having a universal policy regarding account and post content creation can streamline a company’s marketing efforts while ensuring regulatory compliance. Generally, these duties are associated with a company’s Marketing Department.

Account Creation & Maintenance Process

It is a best practice to have all business accounts, for the company or individual LOs, created by the Marketing department and not by individual employee account users. This process further ensures that the account is considered as proprietary business information, indicating a stronger tie to company ownership, which is outlined in most employment agreements. Having uniformed, clearly conspicuous locations for company information (such as a privacy policy, NMLS consumer access, or legal disclosures) and individual LO licensure (both NMLS IDs and state licenses) ensures that consumers and regulators alike can identify your company.

For maintenance, it is a best practice for the Marketing Department to work closely with your HR Department to track new hires and terminations. Your company should clearly identify what your policy is in regard to employees who are terminated from your business, but still maintain a social media account with your brand and information.

Content Creation & Posting Process

Content creation for social media posting, as mentioned, is spearheaded by the company’s Marketing Department. Generally, after content receives approval from the Legal or Compliance Department, it is distributed in mass by the Marketing Department to individual Loan Officers. Loan Officers are often the administrators of their own pages, responding to the public or escalating social media issues to other departments in the organization. Branch or corporate social media account administration may be handled by the branch manager or Marketing Department directly.

Any and all advertisements disseminated and/or published on behalf of your company should clearly and conspicuously include the following required components at a minimum:

  • Company name and contact information (legal name, address, phone, etc.)
  • Company NMLS Unique Identifier
  • All applicable licensing information
  • Corporate logo
  • Equal Housing Lender and non-discrimination logos and statements