On December 17, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced that it has taken action against lead aggregators that resold sensitive personal information to lenders and debt collectors. In a complaint against T3Leads (“T3”) and a consent order against a sole proprietorship (“Lead Publisher”), the CFPB alleged that the lead aggregators exposed millions of consumers to unfair and abusive acts and practices.

T3 COMPLAINT -

In its complaint against T3, which was filed in the Central District of California, the CFPB alleges that T3 bought consumers’ loan applications from lead generators that marketed payday and installment loans and sold the information to lenders and other lead purchasers without properly vetting the sellers and buyers, exposing consumers to the risk of their sensitive personal information being purchased by illegal actors.