On September 6, 2017, the Consumer Financial Protection Bureau announced that it has taken action against an online lead aggregator. The allegations revolved around the company's selling personal information of consumers who were interested in small-dollar or installment loans to online lenders. It was alleged that the loans ultimately offered to consumers were, or were likely to be, void in a consumer's state of residence, meaning that the lender had no legal right to collect the loans. According to the CFPB's consent order, the loans were void in whole or in part because of licensing requirements or interest rate limitations in the consumer's state.
Read our client alert.