ACH for State and Tribe Lenders-Google Payday Loans

By | Jul 21, 2016

Wondering why payday loan ads are still showing in Google Adwords?

[Now Available for tribe and state lenders: ACH, credit card payments, Image Cash Letters (ICL) and ACH transaction verification for NACHA compliance. 24+ banks signed on. Email Jer@TrihouseConsulting.com ]

I just checked my Google search results for “payday loan” on both my cell phones, my laptops, my desktop computers and my iPad. Payday loan ads are still showing. [Confession: I owe Check-N-Go roughly $12 because I clicked on their Google PPC ad. SORRY!]

Google delayed implementation of their new Google PPC adwords program an additional week. And, they’re “rolling it out” in a piecemeal fashion.

Here’s a link to Google’s official Policy Page: Google Payday Loan Adwords Policy.

In a nutshell, this is big brother Google’s payday loan guidelines:

  • When promoting financial services and products, you must comply with state and local regulations for any region that your ads target — for example, include specific disclosures required by local law.
  • Your ad may be disapproved for:
  • Failure to provide legitimate contact information for a physical location for the business being promoted
  • Failure to disclose associated fees
  • Failure to include links to third-party accreditation or endorsement where affiliation is asserted or implied, particularly when it serves to improve the reputation of the site

 

Personal Loans: Google defines personal loans as “lending money from one individual, organization, or entity to an individual consumer on a non-recurring basis, not for the purpose of financing purchase of a fixed asset or education. Personal loan consumers require information about the quality, features, fees, risks, and benefits of loan products in order to make informed decisions about whether to undertake the loan.”

  • Examples: Payday loans, title loans, pawnshops
  • Not included:: Mortgages, car loans, student loans, revolving lines of credit (such as credit cards, personal lines of credit)

“Advertisers for personal loans must prominently disclose additional information on their destination site or app.”

  • Your ad may be disapproved for:
  • Failure to provide minimum and maximum period for repayment
  • Failure to provide maximum Annual Percentage Rate (APR), which generally includes interest rate plus fees and other costs for a year, or similar other rate calculated consistently with local law. [What about tribe – sovereign nation lenders?]
  • Failure to display a representative example of the total cost of the loan, including all applicable fees
  • We want to protect our users from deceptive or harmful financial products.
  • We do not allow the promotion of:
  • Personal loans which require repayment in full in 60 days or less from the date the loan is issued (we refer to these as “Short-term personal loans”). This policy applies to advertisers who offer loans directly, lead generators, and those who connect consumers with third-party lenders.

High APR Personal Loans

  • “In the United States, we do not allow ads for personal loans where the Annual Percentage Rate (APR) is 36% or higher. Advertisers for personal loans in the United States must display their maximum APR, calculated consistently with the Truth in Lending Act (TILA).This policy applies to advertisers who make loans directly, lead generators, and those who connect consumers with third-party lenders.”

So… what about tribe payday lenders? What has Google decided is their fate?

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