CFPB Takes Aim at Digital Marketing Providers with New Interpretive Rule

On August 10, 2022, the Consumer Financial Protection Bureau (“CFPB”) issued an interpretive rule clarifying its position that digital marketers providing consumer financial services companies with customer targeting and advertisement delivery services are subject to the Consumer Financial Protection Act as “service providers.” Critically, the rule takes the position that tech companies offering such marketing services fall within the scope of the CFPB’s unfair, deceptive, and abusive acts or practices (“UDAAP”) enforcement authority. Read our recent Legal Update for more details.