When a comparison site lists a lender, is the lender paying the site, and does that change the order?

Summary

A lender's name on a comparison table does not tell you whether it pays the site. Under the FTC's Endorsement Guides, a payment that could change how you weigh a recommendation has to be disclosed in a way that is hard to miss. For mortgage comparison platforms, the CFPB said in 2023 that giving a lender better placement because it pays, and not by neutral criteria, is a referral fee barred by Section 8 of the Real Estate Settlement Procedures Act (RESPA).

A listing and a payment are two different facts

Some lenders on a comparison site pay it and some have no relationship with it at all, and a logo or a table position will not tell you which. You are really asking two questions. Is money changing hands? And does that money affect who gets listed or where? The disclosure answers the first one. The site's stated method has to answer the second.

What the FTC rule requires

The FTC's rule is in 16 CFR 255.5. When there is a connection between the endorser and the seller "that might materially affect the weight or credibility of the endorsement," and the audience would not expect it, "such connection must be disclosed clearly and conspicuously." Money counts, whether or not the advertiser asked for the endorsement.

The Guides include an affiliate example. A blogger reviews coffee makers and links to sellers, and "whenever a consumer clicks on such a link and buys the product, the blogger receives a portion of the sale." The conclusion: "the reviews should clearly and conspicuously disclose the compensation."

"Clear and conspicuous" has a definition too. The disclosure must be "difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers," and online it "should be unavoidable." One of the Guides' examples finds a disclosure placed only on profile pages inadequate, because people seeing the paid posts "could easily miss" it.

When placement is paid for, mortgage law applies

In an advisory opinion issued in February 2023, the CFPB looked at digital platforms "that enable consumers to comparison shop for mortgages and other real estate settlement services." An operator violates RESPA Section 8, it said, "if the platform provides enhanced placement or otherwise steers consumers to platform participants based on compensation the platform operator receives from those participants," and not on neutral criteria. It added that charging one participant more than others to be included "can be evidence of an illegal referral fee arrangement."

Regulation X defines the loans it covers to include those secured by "a first or subordinate lien on residential real property," and a home equity loan taken on top of a first mortgage is a subordinate lien.

The opinion is not on the list of 67 guidance documents the CFPB withdrew in May 2025. That list did include Circular 2024-01, which dealt with preferencing and steering by digital intermediaries.

How this site handles it

Every list here is sorted by one number, the computed cost at a sale in year 10, lowest first, and the Method page gives the formula. Lenders that publish no price stay on the list with the price left blank. The affiliate disclosure page names each program the site has applied to and whether it pays.

Sources

Written by Kaz (pen name). Figures are copied from providers' published pages on the dates shown. We have not used these products. Corrections: contact form.