We are a large mortgage lender that puts its listing on a website aggregator. We are one of many lenders that are on their website. They even put themselves on their website, which competes with our listing. The aggregator generates leads for us. We compensate this online lead generator for advertising our rates and loan products.
Although the online aggregator provides information about our company and other companies, it does not do any business with us other than advertise our rates and products – although it does provide a page about how customers rate our services – and it’s not involved in making loans, loan approvals, credit screening, or making loans.
Essentially, their role just involves collecting information about potential customers and passing it on to us. We then contact the customer. We’ve been with them for a while; however, now we’re getting complaints. And recently, the CFPB seems to be looking into these types of aggregators. We are concerned that we may get caught up in the CFPB’s investigation.
Maybe you can shed some light on the CFPB’s investigation into online lead-generating platforms like the one we’re on. Supposedly, the customers can compare rates and products and choose a lender.
What is the CFPB’s position on these online platforms that generate leads by online aggregators?