Compliance requirements

Disclosures on the website

Website Requirements

  • Loans issued by Stilt Inc.

Application Requirements

Terms and Conditions - The language of this legal resource does not need to be presented, but consent must be gathered. Typically this is presented in a link and requires the borrowers to check a box to prove consent.
Consent to Electronic Disclosures - The language of this legal resource does not need to be presented, but consent must be gathered. Typically this is presented in a link and requires the borrowers to check a box to prove consent.
Credit Reporting Policy - The language of this legal resource does not need to be presented, but consent must be gathered. Typically this is presented in a link and requires the borrowers to check a box to prove consent.
Credit Pull Authorization - The language of this legal resource does not need to be presented, but consent must be gathered. Typically this is presented in a link and requires the borrowers to check a box to prove consent.
Promissory Note - The language in this doc, specifically the TILA Disclosure Grid located on the first page must be shown to the borrower before consent is provided from the borrower. Best practices include forcing the borrower to view the entire agreement before consent can be provided.

Marketing Disclosures

Must be approved by Stilt’s Compliance Department before they are made live. Content will impact disclosures.

Showing correct TILA disclosures

Following information has to be clearly shown to user via email and on the APP
  • Loan Amount
  • Loan Repayment terms
  • Origination Fee
  • Repayment Start Date
  • APR
  • Prepayment penalty
  • Loan Agreement in Ifram (In the email you can ask them to login and see the offer)
In case of rejection we should clearly show rejection reasoning

Customer care response

To be compliant with the lending law in multiple states, we have to follow a strict communication policy with the customers, platform and Stilt should create policy and agree on way of communication and SLA to make sure we are having the best customer experience

Communication for payments, statements

  • The platform should communicate to users on regular basis about payments due, delays, and applying for payments
  • The platform will communicate properly to users about credit reporting, and the date of reporting