Loan Officer Website Compliance Checklist

A compliant loan officer website needs about 12 things: your name and NMLS ID, your company name and NMLS ID, state license info, an Equal Housing statement or logo, an NMLS Consumer Access link, a privacy policy, accessible design, and clean rate, review and partner content. Start with your footer, because most of the identity items live there.

NA Web Services is a marketing agency, not a law firm or lender, so confirm details with your compliance team.

This is the list we run before a loan officer site goes live. It is grouped by where each item lives on the page, so you can audit your own site in about 15 minutes.

Identity and licensing: what must be on every page

These are the items reviewers check first. PerformLine, which monitors mortgage marketing for lenders, lists the Equal Housing logo, the NMLS ID and the company name among the most common fixes it sees on loan officer marketing.

• Your name as it appears in NMLS. Not a nickname. If you go by "Mike" but NMLS says "Michael," use the NMLS version somewhere visible.
• Your individual NMLS ID. Put it in the footer so it shows on every page, and next to your name on the contact page.
• Your company's legal name and company NMLS ID. Also in the footer.
• State licenses. List the states you are licensed in, with license numbers where your states require them.
• A link to NMLS Consumer Access. Point it at your own record so borrowers can verify you.

Why the footer? Many states write the ID rule into law. North Carolina, for example, requires the unique identifier on advertisements, including websites and other electronic means, and also requires lenders and brokers to link to NMLS Consumer Access on their sites. A footer covers every page with one edit.

Fair lending: the Equal Housing logo or statement

Show the Equal Housing Opportunity or Equal Housing Lender logo, or the matching text, in the footer. For FDIC-supervised banks, the rule says the ad requirement can be met with the logotype and the Equal Housing Lender legend. Your company likely has a preferred version. Ask your compliance team which one, and match it.

Also check your photos and copy. Nothing on the site should suggest you prefer or avoid any group of borrowers.

Rates and loan terms: the Reg Z trigger terms

This is where good sites get into trouble. Under Regulation Z, if an ad states certain terms, it must also state other terms. The Reg Z advertising rule lists four trigger terms:

1. The amount or percentage of any down payment
2. The number of payments or the repayment period
3. The amount of any payment
4. The amount of any finance charge

Use one and you must also show the down payment, the full repayment terms, and the APR, using the words "annual percentage rate." Any rate you show must be stated as an APR.

Implied terms count too. "3% down" and "30-year fixed at $1,850 a month" are both triggers. The simple fix: keep loan program pages general ("low down payment options available") and send rate questions to a quote form. If you show live rates, use a tool your compliance team has approved and that prints the full disclosures.

Reviews and testimonials

Reviews sell. They also carry federal rules. The FTC's rule on consumer reviews and testimonials bans fake reviews, review suppression, and rewards that require a certain sentiment. Courts can impose civil penalties for knowing violations.

• Only post real reviews from real borrowers.
• Do not hand-pick and hide the bad ones while implying you show everything.
• Do not reward five-star reviews. If you thank people for reviews, thank them for any review.
• Keep borrower names and details to what they agreed to share.

Privacy, security and forms

If your site has a lead form or an application link, you are collecting personal information.

• Privacy policy. The FTC's guide to the Gramm-Leach-Bliley Privacy Rule names mortgage brokers among the businesses it covers. Link your company's privacy notice in the footer, or a policy your compliance team approved.
• HTTPS everywhere. No form should load over an unsecured page.
• Short forms. Ask for name, phone, email and loan goal. Leave Social Security numbers and income for your secure application portal.
• Consent language. If you will call or text leads, add the consent wording your company uses under the form.

Accessibility

The Department of Justice says the ADA covers the web offerings of businesses open to the public. Its examples are basic: enough color contrast, alt text on images, captions on videos, and a site you can use with only a keyboard. Contrast and missing alt text are the easiest to miss and the quickest to fix.

Partners and referral content

If your site features real estate agents, builders or other partners, keep RESPA in mind. Section 8 bars giving or taking anything of value for referrals. The CFPB's RESPA FAQs say gifts and promotions count, and there is no exception just because the gift is small. A partner page is fine. Paying for spots on it based on referrals is not.

Pros and cons of running this checklist yourself

Pros

• Free, and most fixes take minutes.
• You know your licensing better than any vendor.
• Catching issues before your compliance team does speeds up approval.

Cons

• State rules differ, and this list cannot cover all 50.
• Rate content and review widgets change over time, so one audit is not enough.
• DIY builders often bury footer settings, which makes the NMLS and Equal Housing items harder than they should be.

A quick audit routine

1. Open your homepage, a loan program page, and your contact page.
2. Check the footer on each for the identity and Equal Housing items.
3. Search the site for "%", "down", "payment" and "$" to find trigger terms.
4. Click every form and review widget.
5. Send the results to your compliance team with screenshots.
6. Repeat every quarter and after any company or license change.

If you have not cleared the site with your company yet, start with our guide on whether a loan officer can have a personal website and how approval usually works.

Want a site that starts compliant?

Every NA Web Services loan officer website shows your NMLS ID, licensed states and Equal Housing on every page, and you can send your compliance team a review link before launch. The LO Site is built free, then $79 a month for hosting and two edits a month, with no contract. See plans and pricing, or request a free preview of your site to see yours first.