Thread Options
#2169871 - 03/23/18 04:12 PM Marketing to "Applicants"
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,597
Once a person applies for a loan with an institution, is the institution able to subsequently market to said person whenever they want? Does the act of applying itself give the institution the right to market for its own purposes? Would it matter in the case of indirect auto lending, where the application comes through a dealer and the dealer "farms" the application out to several lenders?

Return to Top
Marketing
#2169884 - 03/23/18 04:40 PM Re: Marketing to "Applicants" Compliance NABW
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,368
Galveston, TX
You can market to anyone that you want to; barring basing that marketing on a existing credit report and other contractual agreements you may have with your indirect partners.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2169918 - 03/23/18 06:09 PM Re: Marketing to "Applicants" rlcarey
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,597
This may be outside topic, but you seemed to make a more general statement. Isn't there something that requires obtaining their NPPI in a permissible way? If there personal e-mail is not public information for example and you want to market through that method, don't you need to get the e-mail legitimately in order to market?

Return to Top
#2170074 - 03/26/18 04:24 PM Re: Marketing to "Applicants" Compliance NABW
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
If you denied me a loan, then marketed something else to me, I'd be mighty upset....

Return to Top
#2170245 - 03/27/18 01:29 PM Re: Marketing to "Applicants" P*Q
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,597
In this case (indirect Auto), they may have still gotten a loan, it just might have come from another lender. Perhaps the bank didn't even deny it, they could have just taken a better deal with another lender.

Return to Top
#2170267 - 03/27/18 02:23 PM Re: Marketing to "Applicants" Compliance NABW
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,368
Galveston, TX
As I said before - read your indirect contracts. The applicant has to know that their information was sent to you or you turn into a CRA when you communicate your decision back to the dealer. If you send a marketing e-mail, it has to have an opt-out - so if they do not want further communication, all they have to do is say no.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z, MoneyMaker