What is LicenseLink
ActiveComply has created LicenseLink, a comprehensive link that houses licensing information, state-specific disclosures, branch information, and more to help employees acheive consumer compliance on digital assets like social media profiles and websites. Each licensed employee will have a personalized licensing link incorporating their individual licensing information from NMLS Consumer Access.
LicenseLink incorporates this NMLS Consumer Access data set on a weekly basis, ensuring that listed licensing information is consistently up to date for set-it-and-forget-it compliance.
Your institution may be utilizing LicenseLink to meet state licensing requirements and to satisfy other compliance concerns on social media and websites.
Digital Asset Categories
Below are the general categories for the various types of "digital assets":
Limited-bio social media - social media profiles that have a smaller character allotment than other social media platforms. Examples of Limited-bio social media include: Twitter/X, Instagram, and TikTok.
Full-bio social media - social media platforms that allocate larger amounts of characters for the About/bio section on a profile. Examples of Full-bio social media include Facebook, YouTube, Zillow, etc.
Websites - may include corproate website landing pages owned and controlled by the financial institution or customized websites controlled by the individual licensed employee or a webmaster of the employees choice.
It can be difficult to comply with all federal and state-by-state licensing disclosure guidelines on Limited-bio social media given the character count restrictions on social media profiles.
Compliance Risk Assessment
ActiveComply created LicenseLink to better accommodate compliance requirements specifically on Limited-bio social media. However, users often wonder if LicenseLink could be utilized elsewhere to meet compliance requirements. This answer often lies with the institution itself as a risk tolerance decision.
Institutions may at times reference the concept of a "one-click away" rule - where disclosures that cannot be included on an advertisement can be place one-click away from the consumer and still be found compliant. This rule is rooted in the FTC's 2013 Dot Com. Disclosures.
A compliance best practice would be to provide required disclosures as close to the consumer as possible if the advertising medium allows. Lenders have additional character space on Full-bio social media profiles and Website footers for required disclosures since character space is not as restricted. Financial institutions that elect to incorporate LicenseLink across marketing mediums may need to demonstrate this compliance narrative election to their regulator on exams as they occur.
Note: LicenseLink is a premium feature and is not automatically enabled for all accounts. ActiveComply administrators should reach out to [email protected] to learn more on how to enable this feature in an account.
Accounts that already have the LicenseLink feature can follow the below instructions for setup.
Setting Up Your LicenseLink
Step 1: Obtain Your Personalized LicenseLink
LicenseLink URLs may be distributed by a member of the company's adminstrative team, but the formating for each URL is the same and can be copied by any user:
https://activecomp.ly/nmls/ + [enter individual NMLS ID]
For example: https://activecomp.ly/nmls/1763717
Step 2: Adding LicenseLink to Digital Assets
After receiving or creating their own LicenseLink URL in the format listed above, users should add the link to any social media profile or website on which they conduct advertising or solicit business. Ideally, the link should be added to a field that allows the link to be clickable for consumers.
Example LicenseLink page:
