Lead Prediction is a marketing services company. We are not a lender, not a broker, and not an originator. This section sets out the regulatory framework we operate inside and the division of responsibility between us and your firm.
Image · 02-AD-FAIL — a live non-compliant ad: triggering terms, approval claims, and missing disclosures.
Image · 02-AD-PASS — the same offer rewritten to stay inside the compliance lines.
We are paid a flat monthly retainer for marketing services rendered. We are never paid per lead, per appointment, per application, or as any share of a funded loan. Section 8 prohibits fees for the referral of settlement service business, and a per-lead compensation structure risks being construed exactly that way. Our structure removes the question.
No specific interest rate, monthly payment, down payment amount, or term appears in any creative we produce. Stating a triggering term obliges full disclosure of all material terms including APR. Our creative is written to benefit and situation, not to numbers.
All campaigns run under Meta's Special Ad Category for Credit and Housing. That removes age, gender, ZIP-code and detailed-interest targeting, and standard lookalike audiences. We treat those restrictions as a design constraint and build qualification into the form and the creative instead of the targeting.
Your firm's NMLS identifier and Equal Housing marking appear on every asset we produce. Producer-level identifiers are captured at onboarding. Borrowers from states in which you are not licensed are filtered before they reach a producer.
Consent language is presented at the point of submission, and IP address, timestamp and form contents are retained as the consent record. SMS traffic runs on registered A2P 10DLC infrastructure. Consent language is reviewed by counsel and re-reviewed if your licensed-state footprint, script, retry cadence, or routing changes.
We do not publish approval claims, rate guarantees, or projected loan outcomes in any creative. Every claim made in advertising has a documented basis on file.
Every ad, every piece of copy, and every form question is presented to you for written approval before it runs. Nothing you have not seen is published.
| Responsibility | Held by |
|---|---|
| Origination licensing and state registrations | Your firm |
| NMLS identifiers and disclosure requirements specific to your states | Your firm |
| Loan terms, product eligibility, and all borrower advice | Your firm |
| Final approval of all advertising before publication | Your firm |
| Regulatory compliance of your origination process | Your firm |
| Advertising creative built to the constraints above | Lead Prediction |
| Special Ad Category configuration and campaign operation | Lead Prediction |
| Consent capture, consent records, and A2P registration | Lead Prediction |
| State-licence routing configuration | Lead Prediction |
| Retention of substantiation for claims made in creative | Lead Prediction |