On August 10, the CFPB issued an interpretive rule stating that digital marketing providers that are involved in the identification or selection of prospective customers or the selection or placement of content to affect consumer engagement including purchase or adoption behavior, are subject to the CFPB’s jurisdiction. The rule ostensibly clarifies the scope of companies that are “service providers” under the Consumer Financial Protection Act (“CFPA”) to include digital marketing providers, and thereby subjecting them to the CFPB’s authority to prohibit unfair, deceptive, abusive acts or practices (UDAAPs). Continue Reading CFPB’s New Interpretive Rule Sets Sights on Digital Marketing Vendors
Gabriel Khoury is an associate in the Corporate Group in the firm’s Washington, D.C. office. He is the Lead Associate of the Blockchain and Digital Assets Team.