It is important that customers are presented with clear and transparent financing terms and guided through a seamless process. This approach embodies good business and customer-centric practices but it is also required by law.
When you market Bread financing options in connection with your product, these laws and regulations apply to you. Failure to comply can have severe monetary and legal consequences to you.
This page is just an overview of some of the rules you should consider. It is important that you also read the Bread Marketing Compliance Guidelines, which you’ll find in the Bread merchant portal, and provide the document to each of your employees or representatives who will be involved in the marketing process. If you need more specific advice, we encourage you to consult your legal counsel.
Prior Approval: Any marketing materials that mention Bread or any Bread financing options must be reviewed by us prior to use. Marketing materials can include emails, text messages, social media, banner ads, or text on your website. You can submit your materials to Compliance@BreadFinance.com. We strive to approve or provide feedback within 3-5 business days of receipt.
Your marketing must be:
Clear and Complete
The Truth in Lending Act (Regulation Z) is one of the laws which regulates the marketing of financing. It prescribes certain rules around how financing options are presented. Some of the rules you must follow:
- Use “APR”: Advertised rates must always be stated in terms of annual percentage rates (“APR”).
- Use Appropriate Disclosures: Whenever you state a term of repayment or a monthly payment amount (such as an “as low as” amount) you must provide a disclosure that includes the full repayment terms, including the APR, the price of the product, and any other terms of the financing.
- Make Disclosures Clear and Conspicuous. Disclosures must be provided on the same page (or at most one click away) and be at least 10pt font with an asterisk or another indicator clearly tying the copy to the disclosure.
- 0% APR. Use Bread approved disclosures whenever marketing 0% APR financing.
Under the Equal Credit Opportunity Act and other laws, you must not differentiate among applicants for any aspect of Bread financing based on a protected class or a proxy for a protected class. Some of the rules you must follow:
- Don’t discourage a prospective applicant from applying. If a customer has any questions about eligibility, please refer the customer to the Bread FAQ page.
- Do send to Compliance@BreadFinance.com for prior approval any criteria to be used for targeted marketing that references Bread or Bread financing.
Transparent and Honest
Federal and state laws require that you not make any deceptive or misleading statements. Some areas to consider to avoid confusion for your customers:
- Financing options. Only advertise Bread financing options that are actually available to your customers.
- Use of Bread Name. Follow requirements for use of the Bread name found in the [Bread Marketing Compliance Guidelines]. All Bread loans are made by Cross River Bank, Member FDIC.
- Description of Bread Application and Product. Follow Bread guidelines on the description of the Bread application process and the Bread product. Avoid statements that imply that Bread is a revolving, open-end credit product.
- Refund and Cancellation Policies. Make your refund and cancellation policies easily accessible to customers on your website.
- CAN-SPAM. Follow CAN-SPAM requirements whenever sending marketing by email.
If you any questions whatsoever, please reach out to Bread. Our Success team is happy to provide you with templates and examples to simplify compliance. In addition, you can contact Compliance@BreadFinance.com to ask questions or to submit your marketing materials for review.