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When a user enrolls in Credit Score Monitoring, SoFi is authorized to obtain and retain full credit report data from a credit reporting agency on a recurring basis and use that data for targeted advertising, product eligibility targeting, and internal statistical analysis.
This analysis describes what SoFi's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that enrollment in Credit Score Monitoring authorizes SoFi to use full credit report data, including detailed credit history obtained on a recurring basis, for advertising and marketing purposes beyond the monitoring function itself. This use of credit data for advertising purposes engages FCRA considerations regarding permissible purposes for obtaining and using consumer report information.
Interpretive note: Whether the stated use of credit report data for targeted advertising satisfies FCRA permissible purpose requirements is a compliance question that depends on regulatory interpretation and enforcement guidance; the document asserts this use is permitted by the Privacy Notice but does not cite specific statutory authority.
The updated terms establish a time-limited referral promotion running through September 30, 2026, with new eligibility criteria for referrers. To qualify for the higher $75 bonus, referrers must maintain either $100 in combined Invest assets or an eligible direct deposit at the time the referred recipient enrolls. Referrers who do not meet these criteria will receive a lower $50 bonus. The terms also restrict bonuses to new Self-Directed Account openings only, excluding Automated Invest and IRA accounts from referral rewards. Referrals must be completed within the promotion period or they become ineligible. You should verify your account meets the stated asset or direct deposit requirements if you intend to participate in the referral program before the September 30 deadline.
View change record →The updated terms establish new restrictions on how referrers can promote SoFi products and create additional obligations for anyone participating in the referral program. Referrers must now obtain express consent before sending promotional text messages in Washington State, cannot use mass email or commercial advertising to solicit referrals, and must clearly disclose their financial relationship to SoFi in any promotion. The revised terms prohibit making claims about product outcomes, interest rates, or approval odds unless directed to official SoFi webpages, and establish a $10,000 annual cap on cumulative referral and welcome bonuses. Tax reporting obligations now apply, with SoFi reporting bonuses as miscellaneous income to the IRS on Form 1099-MISC. You can review the specific promotional campaign rules for each referral link and ensure compliance with state and platform-specific disclosure requirements before promoting.
View change record →The updated terms establish a Privacy Preference Center that gives you control over which types of cookies and tracking technologies are used on SoFi's website. Previously, SoFi stated that if you did not make a selection, you agreed to use of pixels and tracking technologies shared with social media, advertising, and analytics partners. The revised language divides cookies into categories: Strictly Necessary Cookies (always active, required for site function), Functional Cookies, Performance Cookies, and Targeting Cookies. You can now reject all optional cookies using a 'Reject All' button, manage individual cookie categories, or accept all. The terms note that blocking certain cookies may reduce site functionality and available services. You can change your cookie preferences at any time through the Privacy Preference Center.
View change record →Under this clause, users who enroll in Credit Score Monitoring authorize SoFi to collect their full credit report data on a recurring basis and use it to serve targeted advertisements and product offers. The agreement also states that the credit score presented is obtained from a single bureau and may differ from scores used by other lenders.
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"SoFi will obtain and keep your credit reporting information and use it for the purposes permitted in SoFi's Privacy Notice. SoFi's uses of your information may include: SoFi may use your credit information to serve targeted advertisements to you and other communication based on your information. SoFi may present offers to you for other SoFi products and services using your credit information to identify if you are likely to be eligible or interested. SoFi may use your credit information for statistical analysis to improve SoFi products and services.Excerpt from SoFi's Terms of Service
1. REGULATORY LANDSCAPE: The use of consumer report data obtained through a Credit Score Monitoring service for targeted advertising and marketing purposes may engage the Fair Credit Reporting Act, which restricts permissible purposes for obtaining and using consumer reports. The CFPB has enforcement authority over FCRA compliance by financial institutions and consumer reporting service providers. The FTC also has FCRA enforcement authority. Whether advertising and cross-sell targeting constitutes a permissible purpose under FCRA for consumer report data obtained in the context of a credit monitoring service is a material compliance question that applicable law and regulatory guidance may address. 2. GOVERNANCE EXPOSURE: High. The assertion that credit report data obtained for monitoring purposes may be used for targeted advertising and statistical analysis creates potential FCRA permissible purpose compliance exposure. Legal and compliance teams should assess whether these stated uses satisfy FCRA requirements or require separate authorization. 3. JURISDICTION FLAGS: California residents may have CCPA rights relevant to the use of credit report data for advertising purposes, separate from FCRA protections. State credit reporting laws in some jurisdictions may impose additional restrictions on the use of credit data beyond federal FCRA requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: The agreement discloses that credit data is obtained from a single bureau on a recurring basis; compliance teams should assess whether the data retention and use practices described are reflected in agreements with the credit reporting agency supplying the data. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the stated advertising and statistical analysis uses of credit report data satisfy FCRA permissible purpose requirements, review whether the consent mechanism in these Terms is adequate to authorize those uses under FCRA, and assess whether the GLBA Privacy Notice and any applicable CCPA disclosures adequately cover the scope of credit data use for advertising purposes.
This provision establishes that enrollment in Credit Score Monitoring authorizes SoFi to use full credit report data, including detailed credit history obtained on a recurring basis, for advertising and marketing purposes beyond the monitoring function itself. This use of credit data for advertising purposes engages FCRA considerations regarding permissible purposes for obtaining and using consumer report information.
Under this clause, users who enroll in Credit Score Monitoring authorize SoFi to collect their full credit report data on a recurring basis and use it to serve targeted advertisements and product offers. The agreement also states that the credit score presented is obtained from a single bureau and may differ from scores used by other lenders.
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