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Advertising, marketing, and third party lead generation is increasingly being scrutinized by the Consumer Financial Protection Bureau ("CFPB"), Federal Trade Commission ("FTC"), and state Attorneys General. All three are focused on compliance with restrictions on unfair, deceptive, or abusive practices, restrictions on telemarketing, consumer privacy, and other subject matter or medium specific statutes and regulations.
Government enforcers are issuing civil investigative demands and subpoenas in the areas of education, small dollar lending, debt relief services, mortgage, credit monitoring, business opportunities, coaching and mentoring, and more. Whether you're a lead buyer or seller; or under the scope of an enforcement action/examination by being a service provider to CFPB-supervised entities (such as large banks or non-bank entities), you can’t afford to miss this opportunity.
Learn from attorneys in the trenches what's driving investigations, what to do when you're the target versus a recipient of a third-party request, and ways to avoid scrutiny all together.
Jonathan L. Pompan, Co-Chair, CFPB Task Force, Venable LLP