Fair Lending and Down Payment Registries


By Loren Winzeler

updated 6 months ago

Are down payment registries a violation of fair lending? 

 No.  Down payment registries are permitted and encouraged by lending guidelines from the agencies, including Freddie Mac and FHA.  FHA has promote Bridal Down Payment Gift Registries as far back as 1996.

Are down payment registries and down payment crowd funding available to everyone?

 Yes.  We even have background images and other personalizations that are not wedding specific!

  In our application we designate the Date as the Event Date or Target Date.  Often this is the Wedding Date, practically speaking, but it does not need to be Wedding Related.   

We do lean on the Freddie Mac guidelines from 2017 for eligibility of wedding gift funds. 

Isn't targeting engaged or recently married couples a violation of fair lending or MAPS?  aka 'marital status'...?

 No.  Down payment registries are not a loan program.  We recommend to be careful to separate the down payment registry funding application and any partner mortgage program.   

downpayment.gift is a online Software as a Service (SaaS) application that links to a bank account.  It is not a loan program and it's use does not require the services of the Partner's lending services.

(sidebar:  this is one potential problem we see with the CMG Financial homefundit program.  The crowd funding is linked to a specific loan/lender and thereby it's brokers cannot easily target market the program online.  It is a lending offer.)

We believe 120% in Fair Lending and believe down payment registries open up home ownership to more groups!

What about Facebook and Google restrictions on targeting related to Fair Housing? 

In 2019, Facebook rolled out it's Special Ad Category designation inside the Facebook Ads Manager.

This applies to Housing related, Credit, and Employment related advertisements.

Although down payment registries are not a lending offer, strictly speaking, it is "Housing" related offer.  We support and adhere to Facebook (and Google) new focus on reducing discrimination in their ad platform. We do not recommend running ads directly to a sign up offer for a down payment registry without tagging it as Special Ads Category.  You may get the ads declined and eventually get your ad account shut down.

How do you work around this and we remain compliant?

In our Marketing Programs add-ons, we market the registry and refer/link or 'sponsor' the client's registry with our Partner.  

Special Ad Categories remove the ability to target age, interest target except for a handful of restricted interests, and get specific on geo targeting (no zip codes, narrowest is 15mi radius).

If we are running ads directly to a down payment registry sign up, we will target some of the Special Ads real estate interests and widely geo target the ad.  We'll include call outs in the ad copy and images that announce who it's best for.

When we want to run ads to Engaged or Bridal only audiences, we run ads to content that references and asks and answers questions.  In digital marketing, these are often call native ads. We run ads to informational videos and then video view retargeting the audience with sign up offers.   We run ads to wedding giveaways were will include a prize from downpayment.gift which includes a pledge or contribution to the eligible winner.  We build email lists and send them offers to sign up.  We build website custom audiences and run ads to them.  We build Special Ad Audiences from our current home buyers that have signed up and created a registry.  These Special Ad Audiences are similar to Lookalike Audiences but algorithmically avoid targeting protected groups or excluding protected groups.  

Can we have you speak with our Compliance Department? 

  Yes, please book a call!  Reference compliance will be on the call.


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