Compliance and regulatory position
Sore Thumb Agency is a marketing services company. No NMLS number, no applications, no advice to your borrowers.
The approval gate
Nothing goes live until we send you the full pack for your compliance officer to review and approve in writing: ad copy, creative, the funnel, every quiz question, the text and email templates, the AI conversation rules and the disclosure blocks.
Rules our creative is built to
NMLS and state licensing
Advertising identifies your brokerage by legal name with your NMLS unique identifier, and runs only in states where you are licensed. We hold no licence and never present ourselves as a lender or broker.
Reg Z and TRID advertising
We publish no rate, APR, payment, term, down payment or closing cost figure anywhere. Nothing that would pull trigger terms and the disclosures that come with them into a Meta ad.
No approval language
No approved, pre approved, guaranteed approval, or you qualify. The funnel gathers context. It makes no credit decision and is never presented as one.
ECOA and fair lending
No audience exclusion by age, gender, ZIP or any proxy for a protected class. Meta's housing lending category is applied to every campaign, which enforces broad targeting and removes exclusion options.
UDAAP and FTC substantiation
Every claim has a documented basis on file. We decline angles built on fear or false urgency, even when they perform.
TCPA consent and A2P
Express written consent at submission with IP, timestamp, page URL and form contents retained. Texting runs on registered A2P 10DLC with automatic opt out, inside 9am to 8pm local to the borrower.
Privacy and data
First party data under your brand, state access and deletion requests honoured, and no borrower data sold or shared with another brokerage.
Meta platform policy
Housing lending ads carry their own policy layer, including limits on implying knowledge of a person's finances. Copy never addresses a reader as though we know their balance or their credit.
Lender and investor review
Where your lender or investor requires upline review, assets go out as brief, script, visual and disclosure block together, before anything runs.
What we will and will not publish
We will
- Lead with the question the borrower is already asking
- Identify your brokerage and NMLS identifier on the asset
- Carry Equal Housing wording and the disclosure block for your states
- State that terms depend on credit approval and property
- Submit every asset, including AI message templates, for written approval
- Keep substantiation for every claim on file
We will not
- Publish a rate, APR, payment, term or closing cost figure
- Use approved, pre approved or guaranteed approval
- Imply a credit decision has been made from a quiz answer
- Exclude any audience by age, gender or location proxy
- Promise a saving, a cash out amount or a specific loan size
- Publish anything your compliance function has not approved
Division of responsibility
| Responsibility | Held by |
|---|---|
| Licensing, NMLS registration and state footprint | Your brokerage |
| Loan conversations, applications and disclosures | Your brokerage |
| Credit decisions and pricing | Your brokerage |
| Final written approval of all advertising | Your brokerage |
| Lender or investor review where required | Your brokerage |
| Creative built to the constraints above | Sore Thumb |
| Campaign configuration and platform policy | Sore Thumb |
| Consent capture, records and A2P registration | Sore Thumb |
| State licence routing configuration | Sore Thumb |
| Opt out and privacy request handling | Sore Thumb |
What we do not do, at all
- Originate, broker, take applications for or service mortgage loans
- Advise a borrower on a product, a rate or whether to refinance
- Quote rates, payments, APRs or illustrated savings
- Hold an NMLS number or represent a lender
- Provide legal, tax or compliance advice
- Take compensation tied to a loan, an application or a commission
A summary prepared for review, not legal advice. Where it differs from the executed services agreement, the agreement governs.