Lead Generators
Depending on the types of information displayed to consumers and collected from them by lead generators, various federal and state regulations could apply. Many lead generators unwittingly run afoul of state licensing requirements. They should also be aware of potential UDAAP/UDAP and fair lending issues depending on the content, format and placement of information displayed to consumers. Mortgage lead generators may also violate RESPA section 8 and CFPB Loan Originator Compensation Rules depending on the services they provide, the compensation they receive and whether they “steer” consumers to mortgage brokers, lenders and other settlement service providers. Depending how data is gathered and shared with others, lead generators could also violate federal and state consumer and data privacy laws. Our attorneys have advised some of the very first Internet lead generation platforms and many of the top lead generators on the Internet today.
