Compliance FAQ for Banking Professionals

Yes. Referring a declined loan applicant to an alternative resource is legal and, in some cases, consistent with a bank's obligations under the Equal Credit Opportunity Act (ECOA), which requires that declined applicants be informed of their options. Providing a declined borrower with information about alternative funding sources is a customer service action, not a regulatory violation.

This depends on your employer's internal policies and your institution's compliance framework. At most national and regional banks, personal cash compensation from third parties for customer referrals requires explicit written approval from the institution's compliance department. We do not expect or require bank employees to receive personal compensation. Our program includes a no-fee goodwill track specifically for this situation.

Under the charitable donation track, T.A.G. makes a donation to a 501(c)(3) charitable organization of the referring partner's choice when a referred client is funded. The bank employee receives no personal compensation — the benefit goes entirely to a qualifying nonprofit. The referring partner designates their preferred charity at enrollment. T.A.G. records this as a charitable contribution expense. This structure is fully compliant with federal banking employee compensation restrictions.

You should inform the client that: (1) you are referring them to an independent alternative funding provider, (2) T.A.G. is not affiliated with your institution, and (3) any arrangement between them and T.A.G. is separate from their relationship with your institution. A simple verbal disclosure satisfies this requirement. A written note in the client file is best practice.

Yes. We welcome compliance review and can provide: (1) company documentation and operating history, (2) sample affiliate and partnership agreements, (3) this compliance FAQ, (4) a description of our funding products and disclosure practices, and (5) a reference call with Carlos Torres. Contact funding@towersassetgroup.com to request a compliance package.

No. Information shared by a referred client with T.A.G. is used solely to evaluate and fulfill the funding request. T.A.G. does not sell, share, or transfer client data to third parties for marketing or other purposes. Our privacy policy is available at easy123funding.com/privacy-policy.html.

T.A.G. provides merchant cash advances (MCAs) — commercial transactions in which a business receives an advance of capital in exchange for a portion of future revenues. MCAs are not consumer loans and are not subject to the Truth in Lending Act (TILA) or Regulation Z. However, T.A.G. provides full written disclosure of the advance amount, factor rate, total repayment amount, and estimated term before any agreement is signed. No client is funded without their informed consent to the disclosed terms.

Yes. We offer a Class C Institutional Partnership that includes: (1) a formal written partnership agreement, (2) institutional-level revenue sharing (fees paid to the institution, not individuals), (3) co-branded materials for use in your branch or client communications, (4) adverse action notice insert program, and (5) quarterly reporting on client outcomes. This structure is designed for compliance approval at the institution level. Contact funding@towersassetgroup.com to begin discussions.

All client complaints are handled directly by T.A.G. The referring bank or individual has no liability for any transaction between the client and T.A.G. If a complaint involves a referral you made, please contact Carlos Torres at 330-238-3003 and we will address it immediately.

RESPA Section 8 applies to settlement services in real estate transactions. Referrals for business working capital (not tied to a real estate transaction) are not settlement services and are not subject to RESPA restrictions. If the referred client's funding need is connected to a real estate transaction, consult your compliance officer before making a referral.