Simple steps to ensure your Affirm marketing is compliant with federal financial regulations
To get the full advantage of Affirm, letting your customers know about it is essential. But depending on how you market Affirm, you may need to include a disclosure based on federal financial regulations. Below, we'll take you through when that disclosure is needed, where it should go, and what it should say.
When you DON’T need a Truth In Lending Act (TILA) disclosure
You can mention the following without including a disclosure:
Affirm
Monthly payments
Pay over time
Buy now, pay later
Financing
0% APR
10-30% APR
When you DO need a TILA disclosure
You do need to include a disclosure when you mention one or more of the following ‘trigger’ terms:
Number of payments (e.g. 6 payments)
Period of repayment (e.g. 6 months)
Monthly payment amount (e.g. $60/mo)
Existence of a down payment
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What goes into the disclosure?
The disclosure needs to include:
Purchase price/loan amount
Monthly payment amount
Length of loan term
APR
Potential for down payment
Any other restrictions (e.g., limited time, promo codes not valid with Affirm)
Example TILA Disclosure:
“$995 Acme purchase as low as $83.34/mo over 12 months at 0% APR. A down payment may be required. [Offer expires mm/dd/yy.]”
Note: In your disclosure, you should always use the APR that appears in the Affirm modal on your site.
Where does the disclosure go?
Ideally, the disclosure should go on the same creative as the trigger term—in close proximity, and in a similar font size.
If there isn’t room for the disclosure on the creative, you can include a clear “Learn more” link to a landing page that shows the disclosure and also includes Affirm’s universal disclosure, shown below, in the footer.
The landing page can be either:
A) A product detail page with the Affirm educational modal preloaded (or with the disclosure prominently visible).
OR
B) An Affirm landing page on your site, example below.
Special guidance for email marketing
If the subject line has a trigger term, a disclosure needs to be visible in the body of the email.
If the body of the email has a trigger term, a disclosure needs to be clear and conspicuous and near the CTA
If the email links to a shop page, there’s an additional requirement: Affirm’s universal disclosure should be included in the email footer.
AFFIRM'S UNIVERSAL DISCLOSURE:"Subject to credit check and approval. Down payment may be required. For purchases under $100, limited payment options are available. Affirm loans are made by Cross River Bank, a New Jersey State Chartered Commercial Bank, Member FDIC."
Contact your client success manager or email merchanthelp@affirm.com if you have any questions.
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