When a Mortgage Loan Originator (MLO) uses social media to connect with current, former and prospective clients it is considered a form of advertisement. Facebook, YouTube, Zillow profiles, Redfin Openbook profiles, blogs, smart phone applications, and more all are great ways to get in front of a client. Most Consumer Loan and Mortgage Broker companies are unaware that an MLO may even have such a site, or check the content of these sites.
The Consumer Loan Act (CLA) and Mortgage Broker Practices Act (MBPA) have several requirements and restrictions to advertising, such as:
A Consumer Loan or Mortgage Broker licensee should have procedures in place to do an advertising audit, and procedures to approve new sites and content. Consumer Loan licensees should refer to WAC 208-620-620; WAC 208-620-630; WAC 208-620-622. Mortgage Broker licensees should refer to WAC 208-660-440; WAC 208-660-446; WAC 208-660-500. Both Consumer Loan and Mortgage Broker licensees should refer to Regulation Z 12 CFR Section 1026.24.