But there are rules. So. Many. Rules.
A strong mortgage CRM makes following the rules easier for the whole team. Here are seven features compliance officers need to see in a CRM.
It’s not just for mortgage industry CRMs. Marketing compliance is for everyone.
First up are features desired in all CRMs. They may be required for compliance in mortgage marketing, but some also apply to everyone or are just nice to have so companies can protect their brand.
- Respect for consumer preferences and privacy.
CRM systems of all kinds should honor consumer preferences for receiving messages – or not – and for management of personal information.
Email opt-outs must be invited, logged and honored according to the CAN-SPAM Act. Per the Telephone Consumer Protection Act (TCPA), requests to be excluded from phone calls and text messages should receive the same treatment.
The California Consumer Privacy Act of 2018 (CCPA) is likely a harbinger of privacy requirements to come across the nation. To meet its conditions, CRMs must manage consumer requests to view and/or delete personal information.
- Approval process for messaging.
Approval processes are valued for general marketing compliance to ensure proper branding and messaging for a company. In the mortgage industry, compliance officers typically review marketing materials to ensure rules are followed.
A strong CRM will include processes to facilitate approvals, often through assigned roles and permissions. For example, some user roles may have permission to create a message but must submit the message for approval before they send it. Others may not be able to create messages at all.
- Ability to track and audit communications.
Any CRM should enable marketing managers to track what their users are sending to ensure messaging is staying on brand and to monitor the effectiveness of messages sent.
For the mortgage industry, the ability to track and audit isn’t just nice to have. It can be vital for marketing compliance when a regulator comes knocking.
Strong CRMs empower clients to maintain compliance in mortgage marketing by enabling them to meet typical audit requests through readily available system reports. Staff member experts help fulfill additional, more in-depth requests.
Compliance in mortgage marketing has unique requirements, too.
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There are some additional compliance requirements that won’t be found in other industries.
- Standardization of disclosures and legal statements in communications.
Mortgage companies are required to include disclosures, NMLS numbers, and other licensing information in all messaging. For seamless compliance in mortgage marketing materials, a CRM will enable a user to set these up once, then apply them to all outgoing messages.
For larger companies, the information can vary according to the branch or location. Marketing departments should be able to create templates with required statements for all scenarios. The CRM should apply logic to attach the appropriate licensing or disclosure based on the sender, especially for automated messages.
- Equal Credit Opportunity Act and Fair Housing Act requirements.
An important factor for compliance in mortgage marketing is the targeting of diverse audiences. The ECOA and FHA ensure that no one will be prohibited from purchasing a home or obtaining mortgage credit due to factors such as race, sexual orientation, or disability, among others.
Marketing messages, including imagery, can illustrate a company’s commitment to diversity and credit accessibility. A strong mortgage CRM will include a fair balance in ethnicity for images attached to marketing or educational content.
- Value sharing for cobranded materials.
Compliance in mortgage marketing also must respect the RESPA requirements related to kickbacks. Namely, loan officers and real estate agents may not financially compensate one another to gain referrals.
Despite this prohibition, real estate agents and loan officers still want to build their businesses by co-branding marketing materials. To avoid violating RESPA, compliance officers will look for CRM systems that address value sharing accordingly.
This one’s important enough to list on its own. Not only is the APR required any time interest rates are listed, but it also must appear in the same size, style and location as quoted rates.
A strong CRM system will make this requirement for compliance in mortgage marketing a no-brainer. All materials that contain interest rates will also include APRs, no questions asked, and the APR will be displayed appropriately.
In case compliance officers do not agree with the way the CRM calculates APR, the CRM should provide the ability to edit written materials and to configure APR calculations in online calculators and interactive tools.
To meet all marketing compliance needs, many mortgage companies rely on a CRM system built for the mortgage industry. Unlike general CRMs that simply sell mortgage companies an add-on, an industry-specific platform is more likely to offer the experience and tools that make mortgage compliance officers happy.
Top of Mind was founded specifically to help loan officers build client-for-life relationships. Over the years, we’ve fine-tuned our Surefire CRM to meet compliance officers’ needs and requests. We would love to give you a tour.
As content manager at Top of Mind Networks, Renita develops award-winning marketing materials and strategies for mortgage companies. Throughout her career, Renita has managed public relations and produced both printed and online content for clients in the home building, affordable housing, real estate, mortgage lending, financial planning, and environmental industries. As a ghostwriter, she has contributed to two books on social media marketing. Her work has also been published in numerous print and online trade publications for industries she supports.