Lead Generation Policy

Summary

This template is a lead generation policy that is designed for consumer lending platforms to comply with consumer protection laws and regulations. This template includes practical guidance and drafting notes. Lead generation involves identifying and cultivating consumer interest in targeted products and services for dissemination to third parties and loan originators. The objective of lead generation is to connect companies with prospective customers and borrowers to convert leads into sales. In consumer lending, a lead is a prospective borrower who, directly or indirectly, has indicated his or her interest in purchasing a product or service by taking certain action. Lead generators collect consumer information submitted through online forms and applications. This information is sold to companies, financial institutions, and other providers of consumer financial products and services. As an entity providing such financial products and services, the Consumer Financial Protection Bureau (CFPB) and each of the 50 states are tasked with oversight of those business relationships to ensure lead generators comply with applicable consumer financial laws and regulations. This model policy is designed for consumer lending platforms to comply with consumer protection laws and regulations. For a full listing of key content that can be used by in-house counsel to develop, revise, and implement a company's employee and third-party-related policies, see In-House Company Policies Resource Kit. For a full listing of key materials necessary to develop consumer-related bank policies and procedures central to regulated depository institution operations, see Developing Bank Policies and Procedures Resource Kit. For an overview of federal consumer protection laws and regulations more generally, see Consumer Financial Protection Act Fundamentals and Legal Framework for U.S. Consumer Regulatory Law. For background on the FDCPA, including its background and legislative history, see Federal Fair Lending and Credit Practices Manual § 14.01.