{
  "id": "CMP-051",
  "slug": "cmp-051",
  "title": "A first-party lender must use the phrase the reviewer looks for",
  "statement": "A campaign whose business performs first-party lending must contain the literal phrase \"Direct Lending\" in its description.",
  "rationale": "Lending campaigns are screened against a prohibited category that looks almost identical from the outside — the difference between a licensed lender servicing its own loans and a lead-generation operation is not visible in a sample message. The literal phrase is the marker the screening looks for, so a compliant lender that describes itself in its own words is sorted into the refused pile and given a rejection that reads as a content ban.",
  "layer": "CAMPAIGN",
  "layerSlug": "campaign",
  "object": "campaign.description",
  "severity": "HIGH",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "Twilio"
  ],
  "codes": [
    {
      "provider": "Twilio",
      "code": "30895",
      "remediable": true
    }
  ],
  "applicability": {
    "attributes": {
      "directLending": true
    }
  },
  "applicabilityText": "Applies when `directLending` is true.",
  "universal": false,
  "remediation": "Put the words \"Direct Lending\" in the description alongside your own account of the programme, and keep the directLending attribute true. Done when the phrase appears verbatim rather than as \"we lend directly\".",
  "example": "Harbor Point Lending is a Direct Lending business texting its own borrowers about payment due dates on loans it originated and services itself.",
  "pitfalls": [
    "The attribute and the phrase are separate requirements. Setting directLending true without the phrase leaves the screening with nothing to match on."
  ],
  "notes": "A Twilio phrasing requirement layered on top of the attribute itself. Not provider-tagged: including the phrase costs a compliant lender nothing anywhere else, and a tag would resolve YES on an unknown submission target regardless, so the tag would buy no protection while spending one of the three the registry allows itself.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/campaign/cmp-051/",
  "markdown": "https://ekas.io/rules/10dlc/campaign/cmp-051.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}