CERTAIN DISCLOSURES REGARDING LEAD GENERATION


These disclosures are made to you by ONLINELOANNETWORK.COM ("we" or "us"). Although you are submitting a request for a loan through a website maintained by us (or a website maintained by a third-party lead seller), we are not a lender. The following disclosures describe how we operate and how we will process your loan request ("lead").

1. We are both a lead generator and a lead aggregator. As an aggregator, we have a network of third-party lead generators from which we buy leads and, as both a lead generator and lead aggregator, a separate network of purchasers to whom we sell leads. Third-party lead generators do not know the identities of the lead purchasers in our network or details about the terms of the credit products offered to consumers, and the lead purchasers do not know the identities of the third-party lead generators or the methods they use to attract consumers.

2. Lead generators, including us, operate websites that advertise loans and through which consumers submit loan requests. When we aggregate leads, third-party lead generators sell leads to us, and we resell the leads to lead purchasers. The purchasers are online and offline loan lenders, as well as, in certain instances, data managers, data brokers, and remarketing companies. (Data managers are intermediaries for lenders that outsource their lead-purchasing activities, and data brokers are lead aggregators that have their own networks of lead purchasers to which they sell leads after they purchase them from us.) We do not know the end purchasers of the leads we sell to data managers or data brokers. Remarketing companies buy consumer information to send marketing materials to consumers for products other than the loans for which the consumers have requested information.

3. To filter leads to lead purchasers, we use a "ping tree," which sets the order in which lead purchasers have the option to purchase a given lead from us. The position of each purchaser in the ping tree is determined primarily by the price the purchaser is willing to pay for a lead; the higher the price, the better the purchaser's position in the ping tree.

4. A consumer who submits a loan request on a lead generator's webpage is nearly immediately redirected from that page to a lender's webpage. This automated process takes just seconds, and the consumer is not informed that the loan request has been sold to us or sold by us to a lead purchaser.

5. Before we on-board a prospective third-party lead generator into our network, we perform an introductory review of the lead generator's website to check for misleading or inaccurate statements to consumers. After we on-board a third-party lead generator, we have an automated tool called a "web crawler" in place to monitor lead generator websites daily or weekly for misleading or inaccurate statements. But no technology is perfect, and lead generators can change their websites without any notice to us.

6. Despite our initial investigations and ongoing automated monitoring, we may purchase leads from lead generators whose websites include misrepresentations that are likely to mislead consumers into believing that lenders in our network have been evaluated and meet certain standards. Some lead generators have incorrectly represented that they themselves were lenders. Lead generators sometimes also falsely suggest that they help consumers find the best rates or lowest fees or that they review consumers' loan requests to match them with appropriate lenders. These misstatements may not come to our attention.

7. Neither we nor our lead generators typically provide loans directly to consumers. Our third-party lead generators do not select the lenders that will see a consumer's loan request and have no involvement in or knowledge of the terms of the loan a consumer receives after we sell the lead. Third-party lead generators do nothing more than forward loan request leads to us.

8. We do not know the loan terms that consumers will be offered by lead purchasers, and we make no attempt to match consumers with the best loan for their needs, as consumers may be led to believe by some lead generators. Once we sell the lead, we do not know whether a loan is actually made, or whether the consumer accepts or rejects the lender's terms.

9. We do not require data managers or data brokers to disclose the ultimate purchasers of our leads. We therefore do not know the identity of all lenders that obtain consumer loan request information through our lead-purchaser network.

10. We perform limited initial screening of the lead purchasers in our network for compliance with applicable laws. We also perform ongoing compliance monitoring of lead purchasers. In this screening and monitoring, we rely substantially on information provided by the lead purchasers, without independent verification, and our periodic reviews are generally at intervals no more frequent than annual. There can be no assurance that these limited screening and monitoring activities will eliminate lead purchasers whose services are unsuitable, unfair, deceptive, illegal or at variance from the representations made to us by the lead purchasers.

11. Lead purchasers provide regular feedback to us regarding the quality of our leads, including the number of leads that convert to loans and reasons why leads did not convert. We use this information to refine our lead processing to optimize lead conversion.

12. Some of the lenders to which we sell leads are entities organized by Indian tribes, known as tribal lenders, or organized under the laws of foreign jurisdictions, known as offshore lenders. These lenders typically claim immunity from state regulation, do not comply with the laws of the states where the consumers to whom they make loans are located, and do not concede that they are subject to jurisdiction in a forum convenient to the consumer.

13. Tribal lenders and offshore lenders typically charge higher interest rates than lenders adhering to state laws. Because they charge higher interest rates, these lenders generally are willing to pay more for leads and thus may rank at the top of our ping tree.

14. Many of the tribal lenders among our purchasers offer consumers contracts providing for the application of tribal law to the contracts and providing an exclusive tribal dispute-resolution process.

15. If you are seeking a particular form of credit for which you do not qualify, you may receive solicitations for a different form of credit, a form that you are not seeking. The terms of the credit offered may be inferior to those you were originally seeking. You do not have to accept or respond to these solicitations.

16. We may sell your email address to third parties who will use your address to solicit you for goods and services which you have not requested or which you have not otherwise sought. You do not have to accept or reply to these solicitations.

17. Parties to whom we sell leads, including data managers and brokers, regularly combine the information provided by you with information available about you from other sources, such as public records and credit bureaus, for the purpose of offering you goods and services. Some of these goods and services may be other than those you have requested. You do not have to accept or reply to these offers.
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