Online Advertising for Consumer Financial Products: Fair Lending Issues and Risks

Financial services companies are faced with often complicated and nuanced fair lending issues in the course of launching online advertising campaigns. While they possess a vast ability to target potential customers using alternative data and algorithms, institutions must decide how to review and test their data and models for fair lending risk and how to proceed when using proprietary products from third-party vendors – against a backdrop where technology has evolved much more quickly than the available regulatory guidance. Although the CFPB has indicated it will step back from aggressive enforcement of fair lending laws, the risk of action by states, private plaintiffs, and other federal regulators remains. This webinar will unpack the issues facing Fintechs, banks, and nonbanks as they navigate an uncertain legal environment.

During this webinar, we will discuss the following topics:

• The current state of fair lending laws pertaining to online marketing

• Risks that arise through the use of alternative data and algorithms in targeted marketing campaigns

• Strategies for developing and monitoring marketing models to control for disparate impact risks and minimize regulatory, litigation and public enforcement exposure

• Issues particular to mortgage lenders and small business lenders