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
