CFPB Releases Comparison Shopping Warning
On January 29, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a circular (the “Circular”) detailing what it considers deceptive financial services marketing practices under the Consumer Financial Protection Act (“CFPA”). According to the CFPB, operators of comparison-shopping websites may violate the CFPA by steering consumers to certain products or services based on how the site operators are compensated. Titled “Preferencing and steering practices by digital intermediaries for consumer financial products or services,” the Circular makes clear that product steering compromises the trust of consumers who rely on comparison-shopping websites to operate in their best interests. As our readers are