Lets be clear here – if the lenders and networks actually wanted to stop the criminal activity taking place they could wipe out 95%+ overnight with a few simple steps.
Here is how it could be done:
Refuse To Give Affiliates An Account Without a CCL
This point has been a complete farce so far – there are zero legal reasons that an affiliate could possibly need an affiliate account for, if they have no CCL. The networks should insist on a CCL when they give someone a new affiliate account. They should also be going through their current affiliates and demanding to see proof of their CCL. If they can’t provide one, they should be suspended until they can.
There is absolutely no reason they couldn’t do this – it takes 10 seconds to check whether a CCL is valid or not on the official page.
The simple truth here is that its convenient for everyone to ignore this and let the leads flow in from sites which are not complying with the law.
Allow Loan Applications From Specific Websites Only
Networks should force their affiliates to give a list of websites from which they will allow loan applications to come from. This should be manually checked using the CCL checker above. If the site is listed on a CCL, then the site should be added to an approved list. Again this is another point where there is absolutely no legal reason not to do it – anyone without a proper CCL is breaking the law.
If a site is not on the pre-approved list then the iframe shouldn’t load. This would instantly remove the issue of hacked sites being turned into a payday loan site overnight, as if the iframe can’t load then the loan applications won’t work. To allow this to be enforced, data should only be sent by iframe – its too easy to hide the source of criminal leads using XML post etc.
Actively Look For Hacking And Criminal Conduct
The two steps above would be simple to set up and automate, I appreciate this one would be slightly harder as the networks have thousands of affiliates. But they could certainly prioritise and go through their higher volume affiliates and check for compliance.
How long has paydaymom.co.uk and paydayagent.co.uk being sending criminal leads? They should have been flagged up and removed from the system long ago, but T3leads are choosing not to. They can’t even deny knowing about this, as I told them by email.
The sites could also be monitored for other blatant breaches – like advertising no credit check loans.
So What Happens Next?
We can see what your next steps are – you can either put the above into action and we’ll understand you’re serious about cleaning up the criminal conduct. Or you can ignore me and keep committing crimes.
I don’t expect T3leads to voluntarily put those measures into place so it probably falls to the lenders – T3Leads would have to put them into place if the lenders said they won’t buy leads from them unless they do so.
A Message For The Lenders
So what do you think lenders, are you going to force the networks to play within the law? Or are you going to continue to bury your heads in the sand? I have proof that several of you are completely aware of what is going on – if you don’t do something about it, you’re next in my targets and will be fair game to be featured on this blog. I will also be sending a complete file of my evidence to the OFT, and it will be making perfectly clear, who knew what.