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Marketing and Advertising Guidelines Version 5.0| Effective May 1, 2017

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Page 1: Marketing and Advertising Guidelines › wp-content › uploads › 2018 › 02 › ...Installment loans in the Programs are “closed-end credit” for purposes of Regulation Z and

Marketing and Advertising GuidelinesVersion 5.0| Effective May 1, 2017

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Overview

The GreenSky® Loan Programs offer several types of loan plans to give your customers the flexibility to choose the credit product that meets their needs.

These Marketing Guidelines are not intended to serve as legal advice. As there are specific laws governing advertisements of credit terms and conditions, we recommend you consult legal counsel with regard to any marketing campaign in which you engage.

Our Marketing and Advertising Guidelines outline requirements for promotional materials you use to promote the GreenSky® Program.

Any changes to the marketing language provided in this presentation requires express approval by GreenSky®.

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Installment Loan Marketing Guidelines

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Disclaimer & Logo RequirementsDisclaimer SizeThe required disclaimer must be no smaller font than 1/5 the size of the statement being disclaimed. If 1/5 is smaller than size 8 font, the disclaimer must be in size 8 font.

Size 8 font is the minimum for any disclaimer.

• Example:Ad language is 100 pt. font. 1/5 of 100 is 20. Disclaimer must be minimum 20 pt. font.

• Example:Ad language is 35 pt. font. 1/5 of 35 is 7. Because 7 is less than 8, the Disclaimer must be 8 pt. font.

Disclaimer LocationDisclaimers must be in close proximity and connected with an asterisk or footnote to advertisement language.

Use of the GreenSky® LogoThe GreenSky® logo is a registered trademark of GreenSky, LLC and may only be used with written permission from GreenSky.

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Summary of Requirements

Remember:

• Statements made about financing in marketing materials must be accurate, reflect credit products actually available, and be clear and conspicuous.

• Use short, succinct messages that avoid “triggering terms” that require additional disclaimers.

• Review specific requirements for channel (e.g. online, tv, radio).

• If you offer financing from multiple financing providers, you must distinguish the offers from each company and have the correct disclaimers associated with the correct product.• Do not imply a false sense of urgency. Promotion end dates may not be used in advertising unless a promotion truly expires

and will no longer be available.

• GreenSky® discourages the use of “Same as Cash” and recommends using the term “deferred interest.”

• Avoid using terms such as Same as Cash, Instant Approval, and the GreenSky® logo without our express permission.

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You may use the approved messages provided.

Any variation to the language provided here must be approved by GreenSky® before use.

Installment loans in the Programs are “closed-end credit” for purposes of Regulation Z and the Truth in Lending Act.*

*Regulation Z contains rules regarding advertising such closed-end loans (see, 12 C.F.R. § 1026.24).

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Triggering TermsWhat is a “triggering term”?

• The amount or percentage of any down payment;

• The number of total payments or total period of repayment;

• The amount of any payment; or

• The amount of any finance charge (meaning the dollar amount of the finance charges, not APR)

What does this mean to you?• Federal law requires additional disclaimers when “triggering terms” are used

• If your ad has “triggering terms,” the ad must also include the following information:

– The amount or percentage or any down payment (including the fact no down payment is required);

– The terms of repayment, (including terms of entire repayment period and repayment amounts); and

– The APR(s) for the entire term of the loan.

Contact GreenSky for additional required disclaimers if you use “triggering terms” in your advertisements.

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Example Triggering Term Headlines

to Avoid

• 84 Monthly Payments!

• Payments As Low As $100/Month!

• $0 Interest!

• 3.99% for 48 Months!

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General Financing Advertisements with Minimal Disclosures

When it’s more practical due to space limitations or you want to limit the size of the disclosure, we recommend using general advertising headlines such as the following which only require a short disclaimer.

• General Headline Suggestions that do not reference GreenSky® Products– Realize your dreams today with convenient financing options*– Special financing available*– Ask about our financing options*– Buy now, pay over time!*– Competitive financing available!*– Payments that fit your budget*– Financing that fits your budget*

• General disclosure/footnote (for all of above)– *Subject to credit approval. Ask for details.

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Installment Marketing Material Ad Samples

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What is a No/No? Deferred Interest No/Nos do not require payments during the promo period. If customers wish to avoid paying interest, they must pay entire purchase balance before the end of the promo. The customer will see billed interest on their monthly statements during the promo, but are not required to make payments until after the promo.

Approved Headline Text – If subheadlines are used for the “if paid in full within [X months/promo]” text, the subheadline must be at least 50% of the size of the larger text but can be no less than size 12 font.

No Payments and No Interest if Paid in Full within ___ Months*

No Interest if Paid in Full within Promo*

No Payments. No Interest if Paid in Full in ___ Months*

Approved Marketing Disclaimer*Subject to credit approval. Interest is billed during the promotionalperiod but all interest is waived if the purchase amount is paid beforethe expiration of the promotional period. Financing for GreenSky®

consumer loan programs is provided by federally insured, federal andstate chartered financial institutions without regard to age, race,color, religion, national origin, gender or familial status.

No Interest if Paid in Full with No Payments

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The terms “0%,” “0,” and “Zero” cannot be used when advertising a deferred interest plan.

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What is a No/Yes? Deferred Interest with payments promo plans require customers make minimum monthly payments during the promo. Interest is billed during the promotional period, but all interest is waived if the entire purchase balance is paid in full before the end of the promo.

Approved Headline Text – If subheadlines are used for the “if paid in full within [X months/promo]” text, the subheadline must be at least 50% of the size of the larger text but can be no less than size 12 font.

No Interest if Paid in Full in Promo*No Interest if Paid in Full within ___ Months*

___ Months Deferred Interest*

Approved Marketing Disclaimer*Subject to credit approval. Minimum monthly payments required during thepromotional period. Making minimum monthly payments during thepromotional period will not pay off the entire principal balance. Interest isbilled during the promotional period, but all interest is waived if thepurchase amount is paid in full before the expiration of the promotionalperiod. Financing for GreenSky® consumer loan programs is provided byfederally insured, federal and state chartered financial institutions withoutregard to age, race, color, religion, national origin, gender, or familial status.

No Interest if Paid in Fullwith Payments

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The terms “0%,” “0,” and “Zero” cannot be used when advertising a deferred interest plan.

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What is a Reduced Rate Plan? Reduced rate plans require promotional monthly payments during the promotional period. Principal and interest payments are due following the expiration of the promotional period. Payments based on the balance at the end of the promotional period.

Approved Headline Text

Low Fixed Rate*Low Reduced Rate*

___% APR*

Reduced Rate Plans Available*

Approved Marketing Disclaimer*Fixed APR during the life of the loan. Subject to credit approval.Financing for GreenSky® consumer loan programs is provided byfederally insured, federal and state chartered financial institutionswithout regard to age, race, color, religion, national origin, gender,or familial status.

Payment Plans with Reduced Rates

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What is a Zero Percent APR Plan? 0% APR for the life of the loan. Equal monthly payments during the loan beginning the first month after the purchase window expires.

Approved Headline Text

0% APR for ___ Months*

0% APR Financing for ___ Months*

0% APR Available*

0% APR*

Approved Marketing DisclaimerSee the next page for the marketing disclosures.

Zero Percent APR Plans

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Remember, this is not a deferred interest loan. The terms “0%,” “0,” and “Zero” cannot be used when advertising a deferred interest plan. See the no/no and no/yes slides for deferred interest advertising.

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Zero Percent APR PlansDisclaimers

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Plan Number Disclaimer

6024Subject to credit approval. Fixed APR of 0.00% for 29 months. For each $1,000 financed, 5 months of $0.00 payments followed by 24 amortized payments of $41.67. Financing for GreenSky® consumer loan programs is provided by federally insured, federal and state chartered financial institutions without regard to age, race, color, religion, national origin, gender, or familial status.

6036Subject to credit approval. Fixed APR of 0.00% for 41 months. For each $1,000 financed, 5 months of $0.00 payments followed by 36 amortized payments of $27.78. Financing for GreenSky® consumer loan programs is provided by federally insured, federal and state chartered financial institutions without regard to age, race, color, religion, national origin, gender, or familial status.

6048Subject to credit approval. Fixed APR of 0.00% for 53 months. For each $1,000 financed, 5 months of $0.00 payments followed by 48 amortized payments of $20.83. Financing for GreenSky® consumer loan programs is provided by federally insured, federal and state chartered financial institutions without regard to age, race, color, religion, national origin, gender, or familial status.

6060Subject to credit approval. Fixed APR of 0.00% for 65 months. For each $1,000 financed, 5 months of $0.00 payments followed by 60 amortized payments of $16.67. Financing for GreenSky® consumer loan programs is provided by federally insured, federal and state chartered financial institutions without regard to age, race, color, religion, national origin, gender, or familial status.

6072Subject to credit approval. Fixed APR of 0.00% for 78 months. For each $1,000 financed,6 months of $0.00 payments followed by72 amortized payments of $12.82. Financing for GreenSky® consumer loan programs is provided by federally insured, federal and state chartered financial institutions without regard to age, race, color, religion, national origin, gender, or familial status.

Please include the plan-specific disclaimer below in your advertisements when marketing 0% APR plans.

If you are marketing a 0% APR plan not included here, please contact us for the specific disclaimer.

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Channel-Specific Advertising Guidelines

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Digital AdsVisit GreenSky.com/MerchantKit

to create digital ads.

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Print Ads

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Contact your sales account manager if you need help creating print ads.

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Television/RadioAdvertising Guidelines

In addition to the required disclaimers, television and radio advertisements must include the following:

The annual percentage rate or APR and

A toll-free number and a reference that such number may be used by consumers to obtain information about financing.

TV/Video: Disclosures should appear in a size, color, font, and for a duration sufficient for customers to read and understand the terms.

Radio: Disclosures must be recited in the ad at a speed and volume sufficient for customers to hear and understand.

Remember: Scripts for television & radio must be approved by GreenSky®.17

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Key GreenSky ® Resources

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Customer Service HoursMonday – Saturday: 6:00am–1:00am ETSunday: 8:00am–1:00am ET

Customer ApplicationMobile: Download app at www.greensky.com/mobile

Online: www.greensky.com/consumerPhone: 866-936-0602

We’re here to help!We conduct random quarterly marketing audits. You may receive an email from us requesting your participation.

Customer Service Phone866-936-0602

Merchant Service (Concierge)800-357-1558