What is Affirm?
QUICK AND EASY
Checkout is simple at any store that accepts Affirm. Just enter a few pieces of information for a real-time decision.
NO HIDDEN FEES
Know upfront exactly what you'll owe, with no hidden costs and no surprises.
SAFE & SECURE
Affirm connects directly to online stores. There's no card number to steal, so your account stays secure.
YOU'RE IN CONTROL
Pick a loan that fits your budget. You'll make real progress every month, and at the end of your loan you're free and clear.
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)
Unfair, deceptive, or abusive acts and practices can cause significant financial injury to consumers, erode consumer confidence, and undermine the financial marketplace. UDAAP was established to prevent consumer harm by misleading or deceitful actions.
Preventing UDAAP in advertising
To avoid UDAAP risk, marketing must:
- Include all relevant information
- Be clear and easily understood
- Avoid a false sense of urgency
- Be honest
Additional context
Disclosures don’t eliminate the UDAAP risk
- Disclosures are helpful with providing additional context, but they do not negate misrepresentations, omissions, or other deceitful claims.
Substantiate Claims
- Provide a factual basis that underlies statements about the product.
Honor Promotions & Rebates
- All promotions offered must be honored, including any “risk-free” trials, 0% APR financing, or money-back guarantees.
Intent is irrelevant
- Regulators do not consider whether a company intended to mislead or cause harm when determining violations.
FAIR LENDING
Fair Lending applies to the entire lifecycle of a loan, including the advertisement of the credit product. Fair lending means:
Federal and State laws prohibit discrimination at any stage of a loan's lifecycle, including in the advertising of a credit product. As a partner retailer, when advertising Affirm financing, this means you must avoid discouraging individuals from applying. Retailers cannot impose additional application requirements to the application process.
While a retailer may be inherently attractive to a particular demographic, the retailer should avoid targeting Affirm financing based on customer demographic information, including:
- Race/Ethnicity Color
- Religion
- National origin
- Sex (including sexual orientation or gender identity)
- Familial status/Marital Status
- Disability
- Age (provided the applicant has the capacity to contract)
- Income dependency on a public assistance program
CAN-SPAN Act
The CAN-SPAM Act covers "any electronic mail message the primary purpose of which is the commercial advertisement or promotion of a commercial product or service," including email that promotes content on commercial websites. CAN-SPAM includes business-to-business email. The FTC has provided the below guidance to comply with CAN-SPAM:
- Don’t use false or misleading header information. Your “From,” “To,” “Reply to,” and routing information-including the originating domain name and email address-must be accurate and identify the person or business who initiated the message.
- Don’t use deceptive subject lines. The subject line must accurately reflect the contents of the message.
- Identify the message as an ad. The law gives you a lot of leeway in how to do this, but you must disclose clearly and conspicuously that your message is an advertisement.
- Tell recipients where you’re located. Your message must include your valid physical postal address. This can be your current street address, a post office box you’ve registered with the U.S. Postal Service, or a private mailbox you’ve registered with a commercial mail receiving agency established under Postal Service regulations.
- Tell recipients how to opt out of receiving future emails from you. Your message must include a clear and conspicuous explanation of how the recipient can opt out of getting email from you in the future. Craft the notice in a way that’s easy for an ordinary person to recognize, read, and understand. Creative use of type size, color, and location can improve clarity. Provide a return email address or another easy internet-based method for people to communicate their choice to you. You may create a menu to allow a recipient to opt out of certain types of messages, but you must include the option to stop all commercial messages from you. Make sure your spam filter doesn’t block these opt-out requests.
- Honor opt-out requests promptly. Any opt-out mechanism you offer must be able to process opt-out requests for at least 30 days after you send your message. You must honor a recipient’s opt-out request within 10 business days. You can’t charge a fee, require the recipient to give you any personally identifying information beyond an email address, or make the recipient take any step other than sending a reply email or visiting a single page on an Internet website as a condition for honoring an opt-out request. Once people have told you they don’t want to receive more messages from you, you can’t sell or transfer their email addresses, even in the form of a mailing list. The only exception is that you may transfer the addresses to a company you’ve hired to help you comply with the CAN-SPAM Act.
- Monitor what others are doing on your behalf. The law makes clear that even if you hire another company to handle your email marketing, you can’t contract away your legal responsibility to comply with the law. Both the company whose product is promoted in the message and the company that actually sends the message may be held legally responsible.
- Please see https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business for FAQ’s and email examples.