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How an ad is signed off, kept and taken down

A compliance officer can read every word, show an examiner what ran, and stop it today. This page is that process, step by step, with a sample record.

Sign off first, pay second

No money moves before both reviews are done

A bank cannot commit to a vendor before its compliance officer has seen the words, and we will not charge for an ad that never runs. A market is held for you for 14 days while this happens, and the hold counts against the 3 places in the market. If your reviewer rejects the ad, or ours does, nothing runs and nothing is charged.

  1. You

    Pick a market

    Choose a kind of loan and a state. The market is held for you for 14 days and counts against the cap of 3. Nothing is charged.

  2. You

    Write the ad

    In the builder, with a preview at desktop and phone width. It refuses wording it cannot allow and says why, line by line.

  3. Your reviewer

    Signs off

    A named reviewer at your institution, never the author, reads every line and ticks seven statements. We keep the exact words and the time.

  4. Our reviewer

    Reads it too

    A person at The Lender Report reads the same packet. We can reject an ad and say why. We never edit a word of it.

  5. You

    Pay

    You will pay only then. By card or bank debit, or by invoice on net 30 terms after you accept the order form.

  6. The system

    It runs, and we keep the proof

    On the start date. We capture the page as a reader sees it when it goes live and every 30 days, and keep daily counts of views.

Who does what

Five roles

Who may do what in the flow
RoleWhoMayMay not
AuthorAny active manager of your pageWrite and edit drafts, submit them, pause a running ad.Sign off on an ad they wrote.
ApproverA named reviewer at your institution, up to fiveSign off or reject each line, pause an ad, take it down with a reason.Sign off on an ad they wrote.
Account ownerThe owner of the accountChoose markets, pay or accept the order form, cancel.Skip either review. Nothing is charged before both are done.
Our reviewerA named person at The Lender ReportClear or reject an ad with a reason, take an ad down.Edit a word of your ad. The review list opens only with a key held by the people who review.
The systemThe accounts serviceRun the checks, render the ad, capture proofs, keep the record.Show an ad that is not cleared, in a paused state, or past its dates.

A bank, savings institution or credit union must name at least one approver before its first ad can be submitted. A non-bank with a single manager may sign off its own ad if it ticks every statement; our reviewer sees that, and we recommend a second person.

What your reviewer signs

Seven statements, ticked one by one

  1. I have reviewed this ad and the page it links to. It is accurate and current.
  2. It promotes only commercial-purpose loans. It contains no deposit, insurance or consumer-credit offer.
  3. It complies with the advertising, fair lending, licensing and disclosure rules that apply to [Lender] in every state it targets, including any required statements, logos and license numbers.
  4. For SBA kinds of loan only: it does not state or imply preferential treatment by the SBA or any agency.
  5. Every number in it is supported by the source shown or attached.
  6. I am authorized to approve advertising for [Lender].
  7. I understand The Lender Report will keep a record of this ad, this approval and what ran, and that I can pause it at any time.

The reviewer also decides on each line of the ad: its words, kind of loan, states, dates, link and rate. A rejection needs a note and sends the ad back to its author. The exact words your reviewer sees are stored with each ad. If we ever change a sentence, it becomes a new sentence with a new id, and the old record keeps the old words.

Our review

What we check, and what we cannot do

A named person here reads the same packet your reviewer signed. We also see whether your identity was checked, whether your page is suspended, what changed since the last cleared version, a snapshot of the page your link goes to, and a preview of the page types the ad will run on. We clear the ad or reject it with a reason that goes to its author.

We cannot edit a word of your ad. The Lender Report sells no leads, and nobody who sells here has access to the review list. We have not set a review time, and we will not print one until we can keep it.

Pause and takedown

You can stop it today

  • Pause. Any manager or approver at your institution can pause a running ad at any time. It is off the page within 5 minutes, and resuming it needs no new review because the words have not changed.
  • Takedown. An approver can take an ad down with a reason. A taken-down ad needs a new version, signed off again.
  • Our takedown. We take an ad down within one business day of a flag, and at once if it is urgent. We say why.
  • Ends by itself. An ad stops when the lender closes, merges or loses its charter or license, when a claim proves false, when an order ends, or when a payment is more than 7 days past due.
  • Editing a running ad. It starts a new version. The old version keeps running until the new one is cleared, then they swap.

What we keep

So you can show an examiner what ran

  • Every version of every ad: its exact fields, the page as it renders, and a desktop and a phone picture of it, each with a SHA-256 fingerprint.
  • Every sign-off and every statement ticked, with the exact words shown, the person, the time in UTC and the version.
  • Proof of what ran: a capture when the ad goes live, every 30 days while it is live, and when it ends or comes down.
  • Daily counts of views for each ad, by kind of loan, state and page type.
  • A chain of fingerprints: every record holds the fingerprint of the one before it. The head of the chain is emailed each day to your reviewers and to us. Changing an old record breaks the chain and shows. We call this tamper-evident, not tamper-proof.

How long. We keep ad records for the life of the account and 7 years after. That period is our choice, not a rule. If your policy needs longer, tell us. You can export everything we hold for your institution at any time, as one archive. We do not delete these records on request, except where the law requires it.

The compliance packet

One for each version of an ad, as a PDF and as data

  1. The cover: the lender, its regulator number, the ad, its version, and the history of who did what and when.
  2. The ad as a reader sees it, on a desktop and on a phone, with the Ad label and every required line.
  3. The exact words, character for character, and what changed since the last cleared version.
  4. Where the link goes: the address, the page title and a fingerprint of the page when it was signed off, so a later change on your own site shows.
  5. The required statements shown, and why each one is there.
  6. A source for every number: the fact, its source and date, or the published rate.
  7. The targeting: kind of loan, states and dates, and the sentence "Nothing else is used."
  8. The page types where the ad can run and the ones where it never runs.
  9. Every sign-off: the person, role, time, decision, notes and the statements ticked.
  10. The order: what was ordered, the price, the term, the order form version, the signer and any PO number.
  11. The fingerprints of every proof, and the daily counts once the ad is live.
  12. The head of the chain at the moment of export.

An officer should be able to answer yes to all twelve without leaving the packet. See a sample.

A sample packet

Example Lender is a stand-in. Every value in square brackets is a fill-in

Sample. Not a real record.

Compliance packet

  1. Cover

    Lender: Example Lender, a bank. FDIC certificate [number]. Ad [id], version [number]. History: drafted [date and author]; sent to the reviewer [date]; signed off by [approver] [date]; cleared by us [date]; paid or order form accepted [date]; live [date].

  2. The ad as rendered

    Desktop and phone pictures are in the file. The words and every required line:

    AdExample Lender

    Ad. Paid for by Example Lender. Paid placements are not part of our search results.

    Multifamily loans in Texas

    Made [number] multifamily loans in [year] (HMDA, as of [date]).

    See Example Lender's commercial lending page

    Equal Housing Lender. From Example Lender. Written by Example Lender, not by The Lender Report. Last updated [date]. Commercial-purpose loans only. Legitimate lenders here will not ask you to pay through this site.

  3. Exact text and what changed

    Headline: Multifamily loans in Texas. Body: Made [number] multifamily loans in [year] (HMDA, as of [date]). Link text: See Example Lender's commercial lending page.

    - Made [old number] multifamily loans in [old year]+ Made [new number] multifamily loans in [new year]

  4. Where the link goes

    https://www.yourbank.example/commercial. Page title when signed off: [title]. Page fingerprint: [SHA-256].

  5. Required statements shown, and why

    Ad label and the paid-for line, because a paid placement says so. Commercial-purpose loans only. Equal Housing Lender, because the kind of loan is housing. From Example Lender. Written by Example Lender, not by The Lender Report. Last updated [date].

  6. Sources for every number

    "Made [number] multifamily loans in [year]": fact [id], source HMDA, as of [date], shown with its link on the lender's page.

  7. Targeting

    Kind of loan: Multifamily. State: Texas. Dates: [start] to [end]. Nothing else is used.

  8. Where it can and cannot run

    It can run on Loan Comps and search results for multifamily loans in Texas, and on the hub page for that market where there is one. It never runs on a lender page, a comparison, a ranking, a table of recorded loans or any page in the never list.

  9. Sign-offs

    Person and roleTime (UTC)Decision
    [Author], author[time]Submitted version [number]
    [Approver], approver at Example Lender[time]Signed off every line. Ticked statements [ids]
    [Our reviewer], The Lender Report[time]Cleared. No edit was made

  10. The order

    Market sponsorship: Multifamily in Texas, tier [number], price on the order form, monthly. Order form version [id], signed by [name, title]. PO number [number, if any].

  11. Proofs and counts

    Capture at go-live [date]: desktop [SHA-256], phone [SHA-256]. Daily views by page type: [table, one row a day].

  12. Chain head at export

    Record [number], fingerprint [SHA-256].

A real packet is made for every version of every ad, and an approver can download it as a PDF or as data from the ad's page.

Where an ad can run

  • Loan Comps and search results, for searches that fit your credit box. Not on a search for a lender by name.
  • The hub page of your market: the page for one kind of loan in one state, where the state has one.
  • The state page, for a state ad.

Where it never runs

  • Lender pages, and the pages for one lender and one kind of loan
  • Comparisons
  • Any table of recorded loans
  • Rankings
  • The page for a business owner a bank just turned down
  • For brokers, for borrowers and for lenders
  • Report a problem, how we make money, methodology, sources, terms, privacy, accessibility and license
  • Claim, sign in, account, dashboard and saved lists
  • The API, the MCP server, llms.txt, feeds and sitemaps, unless a caller asks for ads by name
  • Any page that has fewer than three results in its list

The rules an ad runs into, and what the product does

Twelve rows

We are the medium. The advertiser owns the legal duty for its ad. This table says what the product does about each rule. It does not say what the law requires of your institution, and it is not legal advice. Ask your own counsel. Our own counsel has not reviewed this page yet.

Rules an ad runs into and what the product does
RuleWhat it asksWhat the product does
FDIC official advertising statement, 12 CFR 328.6Required in an ad that promotes deposit products or non-specific banking services.Every ad is about a named kind of commercial loan, so it promotes neither. There are no brand-only ads and no deposit ads. We never add the FDIC statement, symbol or sign.
NCUA official advertising statement, 12 CFR 740.5Required in an ad about member accounts, with exceptions.The same. A credit union ad carries "Membership required".
Misstating deposit insurance, 12 CFR 328.102No wording that suggests insurance covers something it does not.The builder refuses wording about insurance, the FDIC or the NCUA. The only insurance text that can appear in an ad is written by the system.
Equal Housing Lender, 12 CFR 338.3 (banks supervised by the FDIC) and 12 CFR 701.31(d) (federal credit unions)A lender advertising a loan on a dwelling shows the logotype and legend.The system adds the legend to every housing ad, whatever the charter. The logotype is added once counsel has cleared its use here.
Fair Housing Act, 42 USC 3605 and 24 CFR 100.75No ad may show a preference or limit, and choosing where to advertise must not shut out part of the housing market.Targeting is by state and kind of loan only. No ZIP code, tract, demographic or customer-list targeting. No delivery optimizing. Equal rotation by the hour.
Equal Credit Opportunity Act and Regulation B, 12 CFR 1002.4(b)No statement, including a picture, that would discourage a reasonable person on a prohibited basis.No pictures of people: the only picture is your own logo. Words that could suggest a preference are noted for your reviewer. Wording about a protected basis is refused.
Truth in Lending, Regulation Z, 12 CFR 1026Advertising rules for consumer credit. Business and agricultural credit is exempt.Business-purpose loans only. No down payment, payment amount or term examples. A rate is an annual rate or APR with its loan type and date, and it drops off after 30 days.
Deposit advertising, Regulation DD, 12 CFR 1030.8Rules for advertising deposit accounts.Outside this product by design. No deposit ads, and the builder refuses APY, CD, savings, checking and money market wording.
Unfair or deceptive acts, FTC Act section 5A claim must not mislead a reasonable reader, and fine print cannot cure a misleading headline.No superlatives and no promises of results. Conditions sit in the same block as the claim. Every number comes from a source.
SBA lender advertising, 13 CFR 120.413A lender may mention its SBA participation. It may not imply SBA favors it or use SBA's seal.Text only and no SBA logo. The SBA name may be used only to say the lender makes SBA 7(a) or 504 loans, where its public SBA record shows it.
Paid placement labeling, FTC native advertising guidanceA paid placement should say so clearly.The word Ad before the name at body size, in a bordered, shaded box, outside the list, marked as a paid link in its code, and kept out of search snippets.
State rulesSome states want disclosures, or a license number, in lender advertising.No specific offers or quotes, ever. A license line is required of a non-bank in each state counsel lists. Ads are paused in eight states until counsel clears each one.

Ad specs Vendor packet Order form