# TikTok Loans Texas — Trainer Guide for UK Call-Centre Operations

## Purpose

This guide supports a training session for UK-based agents handling Texas customer applications and servicing calls for **Maxitech USA, LLC dba TikTok Loans**.

It is based on the uploaded website/disclosure pack, including:

- Texas application journey materials;
- Terms and Conditions;
- Privacy Policy;
- Electronic Communications Consent;
- Marketing Consent;
- Fee Schedule and Consumer Notice;
- Blue Form disclosures;
- CAB licence and CSO registration certificate;
- customer-facing website pages.

This guide is operational training material and should be approved by compliance/legal before agent rollout.

---

## 1. Training objectives

By the end of the session, agents should be able to:

1. Explain the Texas operating model accurately.
2. Distinguish TikTok Loans' role from the lender's role.
3. Verify customers before discussing application or account-specific information.
4. Handle application, privacy, e-consent, marketing consent and payment questions.
5. Avoid statements that could mislead customers or disclose private information.
6. Know when to escalate to compliance, underwriting, complaints or management.

---

## 2. Texas operating model

### Core agent message

In Texas, **TikTok Loans is not the lender**.

TikTok Loans acts as a **Credit Access Business (CAB)** and **Credit Services Organization (CSO)**. It helps customers obtain credit from an unaffiliated third-party lender and then services the account.

### Uploaded disclosure wording

The uploaded materials state:

> Maxitech USA, LLC dba TikTok Loans is licensed as a Credit Access Business (CAB), License No. 2500080092-174229, by the Texas Office of the Consumer Credit Commissioner and registered as a Credit Services Organization (CSO), Registration No. 20240038, by the State of Texas. TikTok Loans is not a lender in the state of Texas. All loans for which TikTok Loans acts as a CSO/CAB are funded by an unaffiliated third-party lender, G4 Finance LLC, and serviced by TikTok Loans.

### Who does what

| Party | Role | Agent explanation |
|---|---|---|
| Maxitech USA, LLC dba TikTok Loans | CAB/CSO and servicer | Helps arrange credit and services the account. |
| G4 Finance LLC | Third-party lender | Funds the loan and makes the credit decision. |
| Customer | Borrower/applicant | Applies for credit and agrees to loan/servicing documents. |
| OCCC | Texas regulator for CAB licence | Handles unresolved regulatory complaints. |
| Texas Secretary of State | CSO registration authority | Registers CSOs. |

### Agent-safe explanation

> TikTok Loans operates as a Credit Access Business and Credit Services Organization in Texas. We help arrange credit from our unaffiliated third-party lender, G4 Finance LLC, and we service the account after funding. TikTok Loans is not the lender in Texas.

### Do not say

- “We are the lender.”
- “TikTok Loans funded your loan.”
- “We made the credit decision.”
- “We guarantee approval.”
- “You have been approved” before proper verification and final checks.

---

## 3. Product and customer journey overview

### Website-level product description

The uploaded website materials describe Texas loans as short-term loans designed for immediate needs, not long-term financial needs.

The uploaded materials include references to:

- loan amounts from **$300 to $1,000** in the about-us page;
- homepage wording referring to loans up to **$2,000**;
- sample disclosures for **$300, $500 and $750** loans;
- terms over approximately **3 to 6 months**;
- biweekly and monthly repayment examples.

This product-range inconsistency should be resolved before final training rollout.

### High-cost product warning

Agents should understand and be able to explain that:

- these are high-cost, short-term credit products;
- they should not be used for long-term financial needs;
- customers with credit difficulties should seek credit counselling;
- refinancing rather than paying in full may create additional charges.

### Customer journey

1. Customer applies online.
2. Customer enters personal, employment, income, expense and bank information.
3. Customer consents to credit checks and electronic disclosures.
4. Underwriting/verification checks are completed.
5. If eligible, documents are presented for electronic signature.
6. If approved and documents are complete, funds are sent to the customer.
7. Repayments are collected according to the agreed schedule.
8. TikTok Loans services the account and handles customer queries.

---

## 4. Application data captured

The uploaded Texas application flow includes fields such as:

- state;
- requested amount;
- pay cycle;
- number of instalments;
- loan purpose;
- first and last name;
- date of birth;
- cell phone;
- email address;
- driver's licence or state ID;
- licence state;
- Social Security number;
- SMS consent;
- residential address;
- residential status;
- months at address;
- employment type;
- industry;
- employer name;
- income per pay cycle;
- next pay date;
- months with employer;
- active military, spouse or dependent status;
- rent, mortgage, living costs and debt repayments;
- bank account name;
- ABA routing number;
- account number;
- credit-check consent.

### Training point

Agents must treat this as highly sensitive personal and financial information. Do not discuss or confirm application details until the caller has been verified.

---

## 5. Verification and privacy standard

### Core rule

> No verification = no application or account discussion.

### New application verification

For new applications, agents may use a stepped process:

| Stage | Verification | What agent may discuss |
|---|---|---|
| Initial contact | Full name + email or phone used on application | Generic acknowledgement only. |
| Before discussing application details | Add DOB + ZIP code/address | Application progress, missing information, next steps. |
| Before sensitive data/decision/payment discussion | Use 3 identifiers and, where appropriate, last 4 SSN or application reference | Credit decision, loan amount, bank/payment, income, SSN, repayment terms. |

### Existing account/servicing verification

Use at least 3 identifiers before discussing account details:

- full name;
- date of birth;
- ZIP code or registered address;
- email or phone on account;
- loan/application reference;
- last payment amount/date;
- last 4 digits of SSN, if required and approved by policy.

### Outbound call rule

On outbound calls, agents should not reveal sensitive details until verified.

Allowed before verification:

> I’m calling from TikTok Loans about a recent application. Before I can discuss any details, I need to confirm I’m speaking with the right person.

Not allowed before verification:

- “Your loan was approved.”
- “Your payment failed.”
- “Your account is overdue.”
- “We need your SSN/bank details.”
- “You applied for a $750 loan.”

---

## 6. Call scripts

### Inbound new application

> Thank you for calling TikTok Loans. Before I discuss any application details, I need to confirm I’m speaking with the applicant. Please confirm your full name and the email address or phone number used on the application.

Then:

> Thank you. Before I go into the application details, please also confirm your date of birth and ZIP code.

### Outbound application follow-up

> I’m calling from TikTok Loans about a recent application. For your security, I need to confirm I’m speaking with the right person before I discuss any details. Could you confirm your full name and the email address or phone number used on the application?

Then:

> Thank you. Please also confirm your date of birth and ZIP code so I can continue.

### Existing account call

> Before I discuss the account, I need to complete security checks to protect your personal and financial information. Please confirm your full name, date of birth and ZIP code.

### Customer refuses verification

> I understand. For your security, I’m unable to discuss application or account information unless verification is completed. You can contact us using the details shown on our website or in your documents.

---

## 7. Privacy policy handling

### What agents need to know

The uploaded Privacy Policy states that TikTok Loans collects and uses personal information for purposes including:

- identity authentication;
- underwriting and funding;
- fraud prevention;
- legal compliance;
- account servicing;
- transaction processing;
- collections;
- customer support;
- required loan documents and communications;
- marketing communications, where consent applies.

The Privacy Policy also states that TikTok Loans uses safeguards such as administrative, technical and physical security controls, including encryption, while acknowledging that no method of transmission or storage is completely secure.

### Agent-safe explanation

> We use your information to process and service your application or account, verify identity, assess eligibility, prevent fraud, comply with legal requirements and communicate with you about your application or account. Further detail is set out in our Privacy Policy.

### Do not improvise

Agents should not promise:

- “Your data is 100% secure.”
- “We never share your data.”
- “We do not use third parties.”
- “We do not carry out credit checks.”

---

## 8. Electronic communications consent

The uploaded Electronic Communications Consent covers electronic delivery of records such as:

- agreements;
- disclosures;
- consent documents;
- fee information;
- statements;
- adverse action notices;
- transaction information;
- other account/application documents.

### Agent-safe explanation

> Electronic consent allows us to provide disclosures, agreements, notices and other records electronically. You can request paper copies or withdraw consent using the contact details in the consent, but withdrawal may affect how we can provide services electronically.

### SMS service messages

The uploaded electronic consent includes service-related SMS notifications, such as:

- statement notifications;
- account information;
- payment reminders;
- missed-payment or past-due alerts.

Agents should explain that SMS service communications are separate from promotional marketing consent.

---

## 9. Marketing consent

The uploaded Marketing Consent covers promotional messages about discounts, promotions and related marketing, including by phone or text.

### Key points

- Marketing consent is not required to receive services.
- Customers may opt out, including by replying STOP where applicable.
- Agents must distinguish marketing consent from service or account communications.

### Agent-safe wording

> Marketing consent is optional and relates to promotional messages. It is separate from service messages about your application or account.

---

## 10. Credit checks and credit data

The uploaded application includes consent to obtain a credit check through Equifax or one or more consumer reporting agencies for underwriting or prequalification.

### Agent-safe explanation

> As part of the application, credit and verification checks may be carried out to assess eligibility and affordability.

### Do not say

- “The credit check does not matter.”
- “We approve everyone.”
- “This will definitely not affect your credit.”
- “I can tell you exactly what the credit bureau reported” unless the agent is trained and authorised to handle that disclosure.

---

## 11. Military status

The application asks whether the customer is active military, a spouse or dependent.

### Training point

This question is important because active-duty servicemembers and covered dependents have special protections under the Military Lending Act.

### Agent-safe explanation

> We ask this because certain military customers and their dependents may have additional legal protections. We need the answer to process the application correctly.

### Escalate if

- the customer says they are active-duty military;
- the customer is unsure whether they are a covered dependent;
- the system result conflicts with the customer's statement;
- the agent is asked to explain legal protections in detail.

---

## 12. Payments, ACH and repayment methods

The uploaded how-it-works page refers to payments being collected by card, ACH or RCC. The uploaded fee schedule includes returned-item fees and late fees.

### Agent-safe explanation

> Repayment methods and timing are set out in your loan and account documents. If you have a payment concern, please contact us before the due date so we can review available options.

### Important control

Agents should not state or imply that a customer must repay by preauthorized recurring electronic fund transfer as a condition of receiving credit.

---

## 13. Late payments and returned items

The uploaded Fee Schedule and Consumer Notice includes:

- a late fee where a payment is in default for 10 or more days;
- a returned-item fee for returned ACH or payment device items;
- OCCC complaint contact details;
- warnings that the product is not for long-term financial needs.

### Agent-safe explanation

> Late or returned payments may result in fees, as described in your agreement and fee schedule. If you expect difficulty making a payment, contact us as soon as possible.

### Escalate if

- the customer disputes a payment;
- the customer alleges unauthorised debit/card/RCC activity;
- the customer says they revoked payment authorisation;
- the customer says a payment caused hardship;
- the customer threatens legal/regulatory action;
- the customer wants to complain.

---

## 14. Complaints and OCCC notice

The uploaded consumer notice provides OCCC contact details for unresolved complaints or questions.

### Agent handling

1. Listen and acknowledge.
2. Verify the customer.
3. Record the complaint clearly.
4. Do not argue or blame the customer.
5. Escalate according to complaint procedure.
6. Provide formal complaint route where required.
7. If the customer asks about the regulator, provide the OCCC contact information from the current approved notice.

### Agent-safe wording

> I’ll record this as a complaint and make sure it is reviewed under our complaints process. If the matter is not resolved to your satisfaction, the consumer notice explains that you may contact the Texas Office of Consumer Credit Commissioner.

---

## 15. Phrasebook

| Customer asks | Agent can say | Avoid saying |
|---|---|---|
| “Are you the lender?” | “In Texas, TikTok Loans is the CAB/CSO and servicer. The lender is G4 Finance LLC.” | “Yes, we are the lender.” |
| “Who funds the loan?” | “The loan is funded by G4 Finance LLC, an unaffiliated third-party lender.” | “TikTok Loans funds it.” |
| “Why do you need my DOB/ZIP?” | “To verify identity before discussing private financial information.” | “Because the system says so.” |
| “Why do you need my SSN?” | “It is used for identity, credit and underwriting checks where required.” | “Everyone has to give it or we cannot talk to you.” |
| “Will you check my credit?” | “Credit and verification checks may be carried out as part of the application.” | “No.” |
| “Can I opt out of marketing?” | “Yes. Marketing consent is optional and you can opt out as described in the consent.” | “No, it is required.” |
| “Can I repay early?” | “Your documents explain early repayment. The website materials state customers may repay early.” | “You cannot repay early.” |
| “I cannot pay.” | “Contacting us early is best. I’ll review the account and escalate if needed.” | “There is nothing we can do.” |

---

## 16. Role-play scenarios

### Scenario 1 — outbound application follow-up

A person answers but refuses to confirm DOB.

Expected behaviour:

- Agent does not disclose outcome or loan terms.
- Agent provides safe callback route.
- Agent records inability to verify.

### Scenario 2 — customer asks if TikTok Loans is the lender

Expected behaviour:

- Agent explains CAB/CSO model.
- Agent states G4 Finance LLC is the unaffiliated third-party lender.
- Agent avoids saying TikTok Loans funds or makes the loan.

### Scenario 3 — customer says they are active-duty military

Expected behaviour:

- Agent does not continue as normal.
- Agent escalates for MLA handling.
- Agent records the statement accurately.

### Scenario 4 — customer says payment was unauthorised

Expected behaviour:

- Agent verifies identity.
- Agent records dispute precisely.
- Agent escalates to payment/dispute handling.
- Agent does not dismiss the concern.

### Scenario 5 — third party answers phone

Expected behaviour:

- Agent does not disclose the application/account.
- Agent leaves a neutral message only where permitted by policy.
- Agent asks the customer to contact TikTok Loans directly.

---

## 17. Knowledge check

1. Is TikTok Loans the lender in Texas?
2. Who funds the loans?
3. What does CAB/CSO mean operationally for agents?
4. What must agents verify before discussing application details?
5. Can an agent disclose approval status before verification?
6. What is the difference between service SMS and marketing consent?
7. What should an agent do if the customer says they are active-duty military?
8. What should an agent do if the customer disputes a payment?
9. What should an agent do if a third party answers an outbound call?
10. Can agents promise that customer data is 100% secure?

### Answers

1. No.
2. G4 Finance LLC, an unaffiliated third-party lender.
3. TikTok Loans arranges/assists with credit and services accounts but does not lend in Texas.
4. At minimum, name plus application contact details initially, then DOB and ZIP/address before details; stronger checks before sensitive information.
5. No.
6. Service SMS relates to account/application servicing; marketing consent relates to promotional messages and is optional.
7. Escalate for MLA handling.
8. Verify, record, and escalate under payment/dispute procedure.
9. Do not disclose the application/account; use a neutral message or callback route.
10. No.

---

## 18. Internal compliance observations from uploaded pack

These observations should be reviewed before go-live and before final agent materials are issued.

1. The CSO certificate in the uploaded ZIP appears to show an effective period ending **June 3, 2025**. Confirm current registration/renewal before launch.
2. Product range appears inconsistent: one page refers to loans up to **$2,000**, another to **$300–$1,000**, and examples show **$300/$500/$750**.
3. Branding appears inconsistent in some materials: **TikTok Loans** vs **Tick Tock Loans**.
4. Contact email appears inconsistent in places: **customerservice@tiktokloans.com** vs **customerservices@tiktokloans.com**.
5. Service-hours wording uses **7am - 16pm CT**, which should be standardised, likely as **7:00am–4:00pm CT**.
6. Some footer/funding wording appears duplicated or truncated and should be reviewed for final customer-facing copy.
7. Ensure approved scripts reflect that **credit decisions are made by the lender**, while TikTok Loans services the account.

---

## 19. Go-live checklist

Before agents take Texas calls:

- Confirm current CAB licence status.
- Confirm current CSO registration status.
- Approve final product amount/term wording.
- Approve final lender/CAB/CSO scripts.
- Approve verification policy for new applications and existing accounts.
- Approve SSN handling procedure.
- Approve payment-authorisation and revocation handling procedure.
- Approve military-status escalation procedure.
- Approve complaint/OCCC handling process.
- Approve privacy, e-consent and marketing-consent FAQs.
- Confirm call recording disclosure and consent process.
- Train agents on data minimisation and no third-party disclosure.
- Complete role plays and quiz sign-off.

---

## 20. Trainer running order

Recommended session length: 90 minutes.

| Time | Activity |
|---:|---|
| 0–10 mins | Introduction and why Texas is different. |
| 10–25 mins | CAB/CSO/lender/servicer model. |
| 25–40 mins | Application journey and sensitive data. |
| 40–55 mins | Verification, privacy and call scripts. |
| 55–65 mins | Consent, credit checks, military status and payments. |
| 65–75 mins | Complaints, arrears and escalations. |
| 75–85 mins | Role plays. |
| 85–90 mins | Knowledge check and sign-off. |