The Mortgage Compliance Dangers of Alignable

Social media is a free tool utilized by millions of sales folks worldwide to promote brand awareness and connect with customers on a more personal level. However, compliance personnel are all too aware of the dangers that social media can sometimes hold, including brand reputation and regulatory compliance. One social media platform, Alignable, poses more potential risk for mortgage industry professionals than some of it’s peers.

Now, perhaps you haven’t heard of Alignable? That is not uncommon. Though the platform went public back in 2014, only within the past two years has it begun to truly proliferate among mortgage loan officers. As stated on their website, Alignable is “the online network where small business owners across North America drive leads and prospects, generate referrals, land new business, build trusted relationships, and share great advice”. There are some key compliance buzz words in that statement, RESPA section 8 being top of mind. Most mortgage lenders are generally only aware of 3 or 4 social media platforms altogether, but regulators are expanding their social media examination pools wider and wider. Here are some key items to be aware of about Alignable:

1. Accounts are named after the “small business”, the financial institution or mortgage lender, and are made to look like corporately controlled accounts. To see who created the page, visitors must view the Our Team section on the right-hand side of the page.
2. People who join Alignable are often invited by a realtor partner. To view all information listed on an Alignable account, you yourself must also be a user. The Invited By segment is not displayed until you become a user. This information can be a clear indication of a consistent referral partner relationship.
3. An account might exist with your branding or for one of your employees, but they may not have created it. At times, Alignable's may be created by a realtor or other referral partner as a way to bolster their own account's connections or to give themselves recommendations under the guise of a business partner. 
4. Profiles include an “Our Ideal Customer” segment. This free form text section can be a pitfall for many licensed employees. There have been instances of specific demographic information, such as “I love helping single moms find the right loan product”, where another protected class may feel excluded (what about single dads? Are they not welcome customers?) giving rise to fair lending concerns. Other times, licensed employees have listed what areas of town the like to serve or specific zip codes they frequently have business in, prompting thoughts on redlining.
5. Recommendations are shared back and forth between Alignable users. Some examples of problematic recommendations/referrals have included mentioning the exchange of things of value, like gift cards & fishing trips, as thanks to referral partners for their continued business, or statements that they only recommend one particular settlement service provider. These arouse suspicions around kickbacks and steering consumers.
6. Everyone is invited at the Alignable table. When a licensed employee first signs up for Alignable, the system allows them to extend an invite to members of their address book. Soon email invites are being sent to processors, loan openers, and other employees creating a higher potential for unlicensed activity. Employees may at times not remember making Alignable accounts through this email process. 

All this being said, it is important to note that not all social media is created the same. Some have more inherent risks for the financial industry than others and must be monitored more closely. Some financial institutions have outlawed it’s use altogether as an employer, while other organizations have taken a wait and see approach, not wanting to rock the sales team boat. No matter where an institution’s risk tolerance level falls, developing a strong social media policy with clear guidelines around specific platform usage is paramount to preventing a social media disaster.