A Minnesota federal district court recently ruled that lead generators for a payday lender could be liable for punitive damages in a class action filed on behalf of all Minnesota residents who used the lender’s website to obtain a payday loan during a specified time period.  An important takeaway from the decision is that a

It appears that Acting Director Mulvaney’s BCFP is about to settle a case that former Director Cordray’s CFPB filed in 2015 against D&D Marketing, which allegedly engages in lead generation for payday, tribal, and offshore lenders under the name T3 Leads.  Based on the docket, the case appears to have been in active, heated litigation

On September 5, 2017, the CFPB entered into a consent order with Zero Parallel, LLC (“Zero Parallel”), an online lead aggregator based in Glendale, California. At the same time, it submitted a proposed order in the U.S. District Court for the Central District of California, where it is litigating with Zero Parallel’s CEO, Davit Gasparyan.

Almost a year ago, on October 30, 2015, the FTC conducted a workshop on lead generation entitled to “Follow the Lead.” We published a three-part series on the workshop highlighting the key takeaways. On September 15, 2016, the FTC published its own staff paper discussing the workshop and providing its own analysis. The

The CFPB announced last week that it has entered into a consent order with an individual who had operated a defunct business that resold consumer leads to settle charges that the business sold leads to debt collectors who used the information to deceive and threaten consumers into paying debts they did not owe.  The debt

This post is the third in a series we’re writing on the FTC’s workshop on online lead generation entitled Follow the Lead. In our first post, we explored how online lead generation works. In our second, we covered the role that disclosures can and should play. Here, we will discuss the allegation

This post is the second in a series we’re writing on the FTC’s workshop on online lead generation entitled Follow the Lead. In our first post, we explored how online lead generation works. Here, we will discuss two fundamental questions surrounding the role that disclosures can and should play in the industry: What

On October 30, the FTC presented a workshop on lead generation entitled Follow the Lead. Online lead generation is an area receiving increased regulatory scrutiny by the FTC and other regulators, including the CFPB. Over the next several days, we will be presenting a series of posts highlighting key issues in the industry and