On September 6, 2017, the Consumer Financial Protection Bureau (CFPB or “the 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 (“Consent Order”), the loans were void in whole or in part because of licensing requirements or interest rate limitations in the consumer’s state.

The CFPB alleged that the lead aggregator, Zero Parallel, LLC, received leads from lead generators, as well as from its own websites, and sold them to online small-dollar or installment lenders. In addition, the CFPB alleged that consumers who submitted their information on a lead generator’s webpage were immediately redirected to the webpage of a lender. According to the CFPB, consumers were unaware that their information was filtered through, or sold by, Zero Parallel during this automated process.