# CMP-051 — A first-party lender must use the phrase the reviewer looks for

> A campaign whose business performs first-party lending must contain the literal phrase "Direct Lending" in its description.

- **Rule ID:** CMP-051
- **Layer:** Campaign (`CAMPAIGN`)
- **Checks:** `campaign.description`
- **Severity:** HIGH — Rejected by at least one carrier or provider, and a common cause of failure at the rest.
- **When it bites:** Gates approval — get this wrong and registration is refused
- **How it is detected:** AI judgement over the submitted form
- **Fix type:** Fix the field — a better value in the form clears it
- **Required by:** Twilio
- **Applies:** Applies when `directLending` is true.
- **Canonical URL:** https://ekas.io/rules/10dlc/campaign/cmp-051/

## Why this rule exists

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.

## How to fix it

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 of a compliant value

```text
Harbor Point Lending is a Direct Lending business texting its own borrowers about payment due dates on loans it originated and services itself.
```

## Common mistakes

- The attribute and the phrase are separate requirements. Setting directLending true without the phrase leaves the screening with nothing to match on.

## Provider rejection codes

| Provider | Code | Resubmission allowed |
| --- | --- | --- |
| Twilio | `30895` | yes |

## 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.