Yearly Archives: 2016


Are there good jobs out there for Advertising Compliance Workers?

Some people, ask me this question? Why would I want to learn more about knowing the rules that apply to mortgage advertisements? Are there real jobs out there that are looking for people who have learned how to do this type of work?

The answer is yes.  We came across just this sort of advertising compliance job earlier this week. Here’s the posting for the “Advertising Compliance Specialist ” job:Beginner's Guide to Mortgage Advertising Compliance 2

[Blank Mortgage Company, (we changed the name to protect the company), a full-service National Mortgage Lender founded in 2003, has an excellent opportunity for an experienced professional who demonstrates diligence and collaboration to fill the role of Advertising Compliance Specialist. With the ever-changing mortgage industry, [Blank Mortgage Company] is looking to add a detail oriented and analytical Advertising Compliance Specialist to complement our strong compliance team. We are growing at an exponential rate and are looking for an experienced team player to help build and evolve our business to the next level.

[Blank Mortgage Company] is a privately held mortgage lender / servicer and …  We have cultivated a positive and energetic team environment where there is ample opportunity to learn, develop, and grow within the company and further your career aspirations.

Job Summary: 

We’re looking for an organized, articulate advertising, marketing, or compliance professional to assist the Compliance Department and the Marketing Team with ongoing review and approval of marketing communications and materials. This position will act as an informational resource and facilitator of assets through the Creative Approval Process.

Responsibilities: 

  • Review and approve all marketing materials, including advertisements, sales literature, websites, business cards, correspondence, etc.
  • Collaborate with Legal, Compliance, and Marketing as it relates to communications.
  • Draft and update disclosures for marketing materials.
  • Research to ensure materials are compliant with applicable laws and regulations.
  • Assist in answering compliance-related inquiries.

The Ideal Candidate: 

  • 1+ year compliance or marketing/advertising experience required.
  • Basic knowledge of the financial services industry, including regulations related to loan marketing and advertising preferred.
  • Bachelor’s Degree in Marketing, Communications, or similar.
  • Strong organizational and research skills.
  • Outstanding attention to detail.
  • Knowledge of marketing principles and strategies.
  • Ability to work independently and excel in a high intensity environment.
  • Ability to handle multiple tasks and effectively complete a variety projects in a timely manner.
  • Exceptional interpersonal, verbal, and written communication abilities, including the ability to communicate effectively and professionally with all levels and areas of the organization.
  • Proficiency with Microsoft Word, Excel, PowerPoint and Outlook.

With this position, [Blank Mortgage Company] offers a full-time schedule coupled with a competitive salary and benefits package, making this a highly sought-after position.
[Blank Mortgage Company]

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Did you see that last line, this is a “highly sought-after position”. Need more training to get ready for this type of job? Consider our Beginner’s Course or our more detailed Five Week Training Course.


3 Way Ad shows ARM, Heloc and 30 Year Fixed

This Postcard Mailer advertises an ARM, Heloc and 30 Year Fixed Rate Loan.  The main offer however is for an ARM.

Notice that the ARM product being offered is a 5-5 ARM.  We don’t see that product that often. Recall that a 5-5 ARM means the rate is fixed (in this case the ad shows an interest rate “as low as 2.75%) for the initial five year period and then the rate will adjust only once every five years. This differs from 5-1 ARMs where the rate can adjust once every 12 months. The index is a 5 year CMT.

Arm Heloc Fixed frontClick on the ad to get a closer view of the detail. We like the way the ARM payment changes are disclosed but the font size is a bit small to manage with ease.  Notice that the ad also discusses rates and payments on a 30 year product though no real offer was made on a fixed rate loan in the ad. It’s a very thorough disclosure of Reg Z required disclosures but may be a bit more than what is needed which forced the lender to use a smaller font size.


FTC Looks to Purchased Search Terms in Deceptive Advertising Complaints

Troutman Sanders law firm put out a good article on two recent FTC enforcements. “Given these decisions, it is particularly important for businesses engaged in internet marketing to carefully consider the search terms they use to drive customers to their websites. If words purporting to describe a product or service would not be accurate when stated directly to consumers through traditional advertising, then businesses should not use those words to describe their goods or services through keywords.”Google adwords and bing

Summary from the Troutman Sanders LLP article: These two companies were charged with deceptive trade practices.
1) Lumos Labs, Inc., the owner of the online “brain game” portal Lumosity was charged for deceptive trade practices for making it sound like their brain puzzle game could help prevent Alzheimer’s disease. The FTC complaint against Lumocity stated: “Defendants have employed an extensive search engine campaign, including through Google AdWords, and have purchased hundreds of keywords, including many variations of words related to memory, attention, intelligence, brain, cognition, dementia, and Alzheimer’s disease.”

2) Stratford, a for profit web-based school offering degrees to students seeking high school diplomas engaged in deceptive trade practices by misrepresenting that their high school equivalency course would give its graduates he program would help students with career advancement and enable them to apply to college (this was not true, the program they offered fell short of the required courses and many employers and colleges did not view this as the equivalent of a high school diploma). “The search terms Strafford bought were “official high school diploma,” “high school diploma equivalent,” and “real high school diploma online,” in order to direct potential students to the Stratford website.”




So what we learn here is we need to be careful about the actual keywords we buy to promote our services if such keywords are not representative of the products or services we are offering. Note that the keyword purchases were a factor among other advertising done by these companies and the totality of the circumstances will likely be reviewed by the regulator to find the violation.

For the entire Troutman Sanders Article – see FTC Looks to Purchased Search Terms in Deceptive Advertising Complaints