Lending Policy

Last Updated: February 10, 2020

You understand and acknowledge that Warmest Dear, LLC’s (collectively, “Warmest Dear, LLC”, “us”, “we”, or “our”) Fair and Responsible Lending Policy (hereafter “Policy”) is intended to be read in conjunction with this Website’s Terms & Conditions and Privacy Policy This Policy is created in an effort to provide you with important information regarding your rights as a consumer and practices that may be applicable to our Network Partners. The contents of this Policy is not designed and should not be construed as legal advice. Any inquiries you may have regarding your loan or the presented loan offers should be addressed with the lender directly.

Introduction

Warmest Dear, LLC is not a lender or party to any loan or other transaction, does not broker loans to lending partners, and does not make loans or credit decisions. We submit the information you provide us to the lending partners in our database who may use a soft credit check to assess your eligibility for a personal loan and may then provide loan offers. Warmest Dear, LLC is committed to working with responsible lending partners who have policies in place to protect consumers against abusive, misleading, or fraudulent lending practices.

You can learn more about our Network Partners assess your eligibility for a loan in our Terms and Conditions. The loan amount of any loan offer, if one is made, will vary depending on the lender, your creditworthiness, and your state’s laws. There is not guarantee you will be presented with any personalized loan offers, or that upon presentation of any personalized loan offers you will qualify for the rates, fees, or terms shown on this site. If you receive a loan offer from one of our lending partners, it is imperative that you review each lender’s terms and conditions before proceeding with an application for a loan. Please note, that at the point of application with the lending partner, you may be subject to a full credit check.

Commitment to Fair and Responsible Lending Practices

Warmest Dear, LLC encourages consumers who feel their lender has violated any aspect of the law or regulatory requirements to file a complaint with the Consumer Finance Bureau, or any applicable enforcing agency.

The Equal Credit Opportunity Act (ECOA). ECOA prohibits discrimination based on race or color, marital status, religion, nationality or national origin, gender, age, income derived from public assistance programs, and the applicant’s exercise of any right under the Consumer Credit Protection Act. This Act applies to any extension of credit.

Fair Credit Reporting Act (FCRA). FCRA is intended to promote correctness, fairness, and confidentiality of information in Consumer Reporting Agency files by requiring the agencies to furnish correct and whole information to businesses when a consumer’s information is being evaluated for insurance, credit, or employment. Under the FCRA, consumers have the right to: (i) know the information within their credit file, (ii) be informed if information in their file has been used against them; (iii) dispute incomplete or erroneous data in their file; (iv) receive one disclosure at no cost every 12 months upon request from each nationwide credit bureau and from nationwide specialty consumer reporting agencies; (v) request a credit score from consumer reporting agencies for a fee; (vi) limit access the consumer’s file to people with a valid need for access; and (vii) limit unsolicited offers of credit and be provided with opt out rights of such communication.

The Truth in Lending Act (TILA). TILA is intended to promote knowledgeable use of consumer credit by requiring written disclosures regarding terms, costs and fees of loans before a consumer takes responsibility for the loan. This act additionally provides consumers the right to withdraw from certain credit dealings involving a lien on the consumer’s dwelling, provides a means for just and timely resolve of credit billing disputes and regulates credit card practices. Please note that this act does not mandate the charges that may be imposed for consumer credit. The lenders in Warmest Dear, LLC’s network are required to provide consumers with clearly written and discernable interest rates, late fees, and any other fees that may be connected with their loan before loan documents are fully executed.

Americans with Disabilities Act (ADA). The ADA prohibits discrimination against qualified individuals by ensuring that these individuals have equivalent access to goods and services offered by private businesses.

APR Disclosure

The Annual Percentage Rate (APR) is the yearly cost of credit, represented as a percentage. The APR includes fees related to originating the loan, not just the interest payments. By law, the lender must show you the APR before you enter into a loan agreement. States have laws limiting the Apr that the lender or partner can charge you. Please read the lender’s terms and conditions before proceeding with a personal loan.

Debt Collection Practices

Warmest Dear, LLC is not a lender, does not fund loans, and does not engage in any kind of practice related to debt collection. Warmest Dear, LLC aims to work only with reputable lenders who adhere to fair debt collections practices and guidelines. Warmest Dear, LLC supports the provisions of the Fair Debt Collection Practices Act (FDCPA) which is enforced by the Federal Trade Commission (FTC). The FDCPA forbids collectors and collection attorneys from using misleading behaviors, harassment, and other unethical practices in an effort to collect debt. The FDCPA additionally stipulates specific hours of the day in which consumers may be contacted. The FDCPA typically does not apply to first party creditors, however, certain states have passed laws similar to the FDCPA that may apply to first party creditors. Some lending partners in Warmest Dear, LLC’s network may collect their own debts and therefore may be subject to state lending or debt collection regulations. If a lender directly or indirectly violates a debt collection law or regulation, we suggest reporting the violation to the FTC.

Implications of Late Payment and Non-Payment

If you obtain a loan, it is vital that you understand implications that could result from making a payment late or from failing to make a payment. Each lending partner determines their own policy regarding fees that may be charged and/or other consequences from late or non-payments. Consequences can include added charges, negative implications to your credit history and score, collections, and more. We advise you to thoroughly review the payment policies provided in your loan documents before signing so you may understanding the policy and any potential fees or penalties associated with late or non-payments.

State Regulations

Warmest Dear, LLC has a due diligence process in place to help ensure that our lending partners are abiding by the applicable state and federal regulations. However, Warmest Dear, LLC is not responsible for any actions conducted from sources outside its control. Individual states may have their own regulations for lending, including laws pertaining to interest rate limitations, rollover terms, fees, loan terms, recession periods, etc. While Warmest Dear, LLC has policies and procedures in place to ensure the lending partners within our network comply with all federal and state regulations, it is necessary for each consumer to educate themselves about their loan offer prior to considering whether or not to accept the offer. This includes the federal and state laws, rules, and regulations that apply.