Review each material for truth and substantiation before submission
Marketing Compliance policy, §4.1, §5.1
Before any marketing material goes to the sponsor bank, the Compliance Officer reviews it against every substantive requirement: each claim about features, benefits, fees, rates, or terms is supported by current program documentation; comparative claims are substantiated and current; disclaimers are clear, conspicuous, and next to the claim they qualify; no material fact is omitted; and any endorsement or testimonial reflects a real user’s honest experience and discloses any material connection. Material that would reach consumers is flagged as UDAAP-relevant for additional review.
Event-driven
Each marketing material, before submission to the sponsor bank
Complete the review checklist against Section 5, attach the substantiation for each claim, return the draft with required changes, and sign off on the version intended for the sponsor bank.
- Review checklist
Per material: each requirement checked, reviewer, date, sign-off version
- Substantiation file
The program document or data behind each claim, linked to the claim
Compliance Officer
A person must do the work; Leela can track it and file the evidence.
Leela can run the checklist and flag claims with no substantiation attached, but a person decides whether a claim is proven.
Tell Leela about your company to see whether this applies.
Tell Leela how you handle it today, or hand it over: see what’s next.