Fair Lending Risks for Lenders Using Targeted Internet Marketing

In Client and Friends Memos by BMG Memorandum

The current issue of the Federal Reserve Board’s Consumer Compliance Outlook (Third Issue 2019) includes an article entitled “From Catalogs to Clicks: The Fair Lending Implications of Targeted, Internet Marketing,” which discusses the risks to lenders using targeted Internet-based marketing of consumer credit products designed to reach specific categories of consumers. The article focuses on the increased use of Internet-based marketing practices to target audiences by personal characteristics, location and other personal information that may classify consumers by prohibited characteristics protected under fair lending laws.

 

Full Memorandum