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. … Continue Reading
Lead Generation
Is Online Lead Generation Inherently Deceptive?
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 the CFPB and certain consumer groups raise that the industry is “inherently deceptive.”… Continue Reading
Disclosure Confusion in the Online Lead Generation Industry
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 should be disclosed to consumers?… Continue Reading
The Five Stages of Online Lead Generation
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 likely targets for CFPB and FTC enforcement activity.… Continue Reading