ITMedia Misused Millions of Credit Scores for Illegal Profit

Corporate Corruption Case Study: ITMedia & Its Impact on Vulnerable Consumers

Table of Contents

  • Introduction: A Betrayal of Trust
  • Inside the Allegations: A Web of Deception
  • Regulatory Capture & Loopholes: Exploiting the System
  • Profit-Maximization at All Costs: Data as Commodity
  • The Economic Fallout: Consumer Harm Amplified
  • Public Health Risks: The Dangers of Data Misuse
  • Exploitation of Workers: N/A (Not detailed in source)
  • Community Impact: N/A (Not detailed in source)
  • The PR Machine: Misleading Promises
  • Wealth Disparity & Corporate Greed: A Systemic Issue
  • Global Parallels: A Pattern of Predation
  • Corporate Accountability Fails the Public: Knowing Violations?
  • Pathways for Reform & Consumer Advocacy
  • Modular Commentary: Legal Minimalism
  • Modular Commentary: Profiting from Complexity
  • Modular Commentary: This Is the System Working as Intended
  • Conclusion
  • Frivolous or Serious Lawsuit?

Introduction: A Betrayal of Trust

Millions of Americans, often facing financial distress, turn online seeking loans. They submit deeply personal information – Social Security numbers, bank accounts, income details – believing they are dealing with legitimate services connecting them to lenders. Yet, a Federal Trade Commission (FTC) legal complaint paints a disturbing picture of one company, ITMedia Solutions LLC and its affiliates (collectively “ITMedia”), allegedly exploiting this vulnerability on a massive scale. Instead of safeguarding sensitive data and connecting users solely with loan providers as promised, ITMedia is accused of operating a system that treats consumers’ private information as a commodity, selling it indiscriminately to a vast network of entities, many of whom are not lenders at all. This blatant betrayal goes beyond mere deception; it points to potential violations of federal law and highlights systemic failures where profit motives eclipse consumer protection

Inside the Allegations: A Web of Deception

The core of the FTC’s complaint against ITMedia, its holding companies (like XYZ LLC and 123 LLC), numerous controlled LLCs, and several individuals, revolves around deceptive and unfair practices.

Misleading Promises: ITMedia operated hundreds of websites (including domains like cashadvance.com, personalloans.com, and badcreditloans.com) promising to connect consumers with a “network of trusted lenders”. Consumers were assured their submitted data would only be shared with “qualified lenders” or “professional lenders” to secure a loan. Some sites even claimed loans were available “regardless of your credit rating” or that credit scores were not required and would not affect loan terms!

The Reality of Data Sales: Contrary to these representations, the FTC alleges ITMedia distributed and sold consumer information, including highly sensitive data like Social Security and bank account numbers, as “leads” in a marketplace. Critically, ITMedia allegedly did not require buyers to be lenders or to use the data solely for offering loans. The data was allegedly sold to entities including:

  • Businesses illegally marketing loans!
  • Debt negotiation and credit repair services!
  • Pre-paid debit card sellers!
  • Marketers licensing data for emails, texts, and telemarketing!
  • Lead aggregators who further shared the data with unknown entities!
  • Companies whose business purpose was unknown to ITMedia!

The complaint states that since January 2016, for the vast majority (over 84%) of consumers submitting applications, ITMedia either sold their information to non-lenders, used it for targeted marketing data, or directed consumers to online ads. Even when data went to actual lenders, ITMedia allegedly did not require them to use it solely for loan offers and sometimes expressly permitted non-loan marketing.

Fair Credit Reporting Act (FCRA) Violations: The complaint further alleges violations of the FCRA. ITMedia is accused of purchasing credit scores for millions of consumers since 2014 and using them impermissibly:

  • As a factor in maximizing lead sales.
  • To set higher prices for leads of consumers with better scores.
  • To communicate score ranges (sometimes as narrow as 10-20 points) to potential buyers.
  • To filter leads based on buyer-selected score ranges, effectively selling targeted consumer report information.

Using credit reports for lead evaluation, pricing, filtering, or marketing (outside specific FCRA exceptions not applicable here) is alleged to be impermissible. ITMedia allegedly represented to the credit reporting agency that it used scores for “pre-qualification” but failed to disclose the marketing uses or the identities of the end-users receiving the score-based data. The FTC claims ITMedia failed to establish reasonable procedures to ensure resold report information was used only for permissible purposes, failed to verify end-user identities and certifications, and failed to disclose end-users to the original credit reporting agency. These alleged actions constitute knowing violations, potentially triggering civil penalties!

Unfair Data Handling: The FTC contends ITMedia’s practice of distributing unmasked sensitive data (including Social Security and bank account numbers) broadly, even to entities that hadn’t purchased the specific application, was an unfair practice. Despite having data security policies on paper since around 2015, ITMedia allegedly lacked adequate procedures to assess if buyers safeguarded data or used it properly. They allegedly failed to monitor data use through techniques like seeding and did not vet buyers’ security policies effectively. Sharing sensitive data with entities whose location, business, or purpose was unknown exposed consumers to substantial, unavoidable risks like identity theft and fraud.

Regulatory Capture & Loopholes: Exploiting the System

While the complaint focuses on ITMedia’s alleged direct violations, it implicitly points to a system ripe for exploitation. The existence of a sprawling lead generation market, where sensitive data changes hands rapidly between numerous players, suggests regulatory gaps or weak enforcement.

  • The FCRA’s Limits: The FCRA establishes permissible purposes for using credit reports. However, ITMedia allegedly circumvented these by obtaining scores under one pretext (pre-qualification) while using them for another (marketing, pricing, filtering) and failing to ensure downstream compliance. This highlights how determined actors can potentially operate within the gray areas or in direct violation of laws designed to protect consumer privacy.
  • Lack of Oversight: The complaint details ITMedia’s alleged failure to vet or monitor its data buyers. It sold data to entities whose legitimacy or intent was unclear. This suggests a lack of enforced industry standards or regulatory mechanisms mandating due diligence in the data broker ecosystem. The burden fell entirely on the consumer, who was often unaware their data was being sold far beyond the initial promise of finding a lender!
  • Fine Print vs. Bold Promises: ITMedia allegedly used inconspicuous fine-print disclaimers, terms, and privacy policies that contradicted their main advertising messages. Pages listing “Third Parties” (including non-lenders) were often hidden or unlinked from the main application process. This common tactic relies on the unlikelihood of consumers reading dense legalese, allowing companies to claim formal disclosure while actively misleading through prominent marketing. This points to a weakness where formal, buried disclosure can legally overshadow clear, deceptive advertising.

Systemic Commentary: Under neoliberal capitalism, deregulation often creates environments where industries like online lead generation can flourish with minimal oversight. The focus shifts from proactive consumer protection to reactive enforcement after harm occurs. Regulatory capture, where industry interests heavily influence regulations and enforcement priorities, can further weaken protections. ITMedia’s alleged actions fit a pattern seen across industries where complex operations and legal loopholes are exploited for profit, often at the expense of the most vulnerable consumers.

Profit-Maximization at All Costs: Data as Commodity

ITMedia’s alleged business model treated sensitive consumer financial data not as a trusted deposit, but as raw material to be packaged, priced, and sold for maximum revenue.

  • Selling to the Highest Bidder: The lead marketplace operated by ITMedia involved entities bidding against each other for consumer information. This inherently prioritizes revenue over the consumer’s stated need (finding a loan).
  • Monetizing Rejection: When ITMedia couldn’t sell data in the primary marketplace, it allegedly offered “declined” consumer data to other entities or directed consumers to ads, seeking compensation. This shows a drive to extract value from every piece of data, regardless of the consumer’s outcome or expectation.
  • Pricing Based on Sensitivity/Value: Using credit scores to price leads higher for consumers with better scores directly commodifies a consumer’s financial standing for marketing purposes, a practice the FTC alleges violates the FCRA!
  • Ignoring Warnings: The complaint notes that ITMedia’s own online lending trade organization had warned against representing loans were available without credit checks since 2012 because it was misleading. ITMedia’s alleged continued use of such claims suggests a prioritization of attracting applicants (and their data) over adherence to industry best practices or truthful advertising.

Systemic Commentary: This alleged behavior exemplifies the profit-maximization imperative inherent in many capitalist structures, particularly in their late-stage or neoliberal forms. Shareholder value and revenue growth often become the primary metrics of success, incentivizing companies to push ethical and legal boundaries. When consumer data itself becomes a primary product, the incentive is to collect more and sell it more widely, often conflicting with consumer privacy and expectations. The alleged actions demonstrate how the pursuit of profit can lead to the systemic exploitation of consumer vulnerability.

The Economic Fallout: Consumer Harm Amplified

While the complaint focuses on the deceptive practices and data misuse, the potential economic fallout for consumers is significant.

  • Exposure to Predatory Actors: By allegedly selling data to non-lenders, marketers, and unknown entities, ITMedia exposed consumers seeking financial help to a wider net of potential solicitation, scams, or predatory offers unrelated to their original loan request.
  • Identity Theft and Fraud: The broad dissemination of unmasked sensitive data like Social Security numbers and bank account details creates substantial risk. Such data is actively used by criminals for identity theft, applying for credit in victims’ names, filing fraudulent tax returns, creating phantom debts for collection harassment, or unauthorized billing. Consumers could face ruined credit, financial losses, and immense difficulty clearing their names. Some consumers complained of receiving sham loan offers or fake debt collection demands using ITMedia site names shortly after applying!
  • Wasted Time and Effort: Consumers searching for loans invested time and exposed sensitive information based on misleading promises, only to have their data allegedly sold for unrelated marketing purposes. This represents a direct cost in time and potential exposure with no corresponding benefit for many users.

Systemic Commentary: In a neoliberal economic system that often prioritizes corporate freedom over consumer protection, the costs of corporate misconduct are frequently externalized onto individuals and society. The financial and emotional burden of dealing with identity theft, fraud, or relentless unwanted marketing falls on the consumer, while the company allegedly profits from the initial data sale. This case illustrates how inadequate regulation and enforcement can lead to significant, widespread consumer injury!

Public Health Risks: The Dangers of Data Misuse

The primary risk highlighted is financial, specifically identity theft and related fraud. The complaint alleges that ITMedia’s indiscriminate sharing of sensitive personal and financial information (names, addresses, SSNs, bank accounts, etc.) exposes consumers to substantial harm. This type of data is precisely what identity thieves use to open fraudulent accounts, damage credit, intercept tax refunds, or engage in phantom debt collection. While not a direct “public health” risk in the traditional sense, the stress, financial ruin, and time required to recover from identity theft can have severe impacts on an individual’s well-being. The complaint documents consumer complaints linking ITMedia applications to subsequent sham offers or fake debt demands, illustrating the real-world risks.

Exploitation of Workers

The provided legal document focuses entirely on the company’s alleged deceptive and unfair practices towards consumers and its handling of consumer data. There are no allegations or details regarding wage theft, workplace injuries, labor misclassification, or unsafe working conditions within ITMedia or its affiliates.

Community Impact: Local Lives Undermined

The legal complaint details the corporate structure, business practices related to online lead generation, alleged misrepresentations, and data handling failures. It does not contain information regarding community-level impacts such as neighborhood displacement, environmental contamination, infrastructure strain, or other localized consequences stemming from ITMedia’s operations. The harm described is primarily directed at individual consumers across the United States who used their websites!

The PR Machine: Misleading Promises

The core of the FTC’s case rests on the allegation that ITMedia’s public-facing promises were fundamentally misleading.

  • False Assurances: Websites prominently assured users their data would only go to a “trusted network of lenders” or “qualified lenders” solely to find them a loan. Specific sections explained why information was needed, reinforcing the idea it was only for lender review (e.g., contact info for approval notification, bank info for identity verification by lenders).
  • “No Credit Check” Lures: Claims that loans were available “regardless of your credit rating” or without credit score requirements directly targeted vulnerable consumers and were allegedly false or unsubstantiated, contradicting standard lending practices and even warnings from ITMedia’s own trade group!
  • Hidden Contradictions: While making these bold promises, ITMedia allegedly buried contradictory information in fine print, lengthy terms, or obscure “Third Parties” pages that listed non-lenders and were often not linked from the main application flow. This suggests a deliberate strategy of presenting one message prominently while relying on buried legal text for cover.

Systemic Commentary: This pattern aligns with corporate spin tactics common in industries facing scrutiny. Bold, reassuring marketing messages create trust and encourage engagement (data submission), while complex, hard-to-find legal disclosures provide a veneer of compliance. Under neoliberal frameworks that emphasize self-regulation and minimal intervention, such discrepancies between marketing and reality can persist until challenged by regulators or lawsuits.

Wealth Disparity & Corporate Greed: A Systemic Issue

The alleged actions of ITMedia can be viewed through the lens of wealth disparity and corporate greed inherent in certain economic structures.

  • Exploiting Need: The business model targeted consumers often in financial distress, seeking payday or personal loans, sometimes specifically those with bad credit. It allegedly profited by taking their most sensitive data, provided in a moment of vulnerability, and selling it widely!
  • Data as Wealth: In the digital economy, data is a valuable asset. ITMedia allegedly built a business turning personal consumer data into revenue streams, selling it to marketers, debt services, and others far removed from the consumer’s original intent. This reflects a broader trend where corporations accumulate wealth by controlling and monetizing information flows.
  • Complex Structures: The use of multiple holding companies (XYZ LLC owning 123 LLC, which owns ITMedia Solutions, DEV.XYZ, TEAM.XYZ) and numerous controlled LLCs, some registered out-of-state or under tribal law, can serve to obscure ownership and potentially shield assets or complicate accountability—tactics sometimes associated with maximizing profit and minimizing liability.

Systemic Commentary: Neoliberal capitalism often correlates with increasing wealth inequality. Systems that prioritize deregulation and shareholder value can incentivize corporations to extract maximum profit, sometimes through ethically questionable means like exploiting vulnerable populations or commodifying private data. The ITMedia case, as alleged, serves as an example of how these systemic pressures can manifest, potentially enriching owners and executives by leveraging the financial precarity of others.

Global Parallels: A Pattern of Predation

While the complaint focuses specifically on ITMedia and its operations primarily targeting US consumers, the alleged business model echoes patterns seen globally in the digital age under capitalist frameworks.

  • Data Brokering: The practice of collecting consumer data under one premise (e.g., providing a service, finding a loan) and then selling it for unrelated marketing or other purposes is a widespread issue involving data brokers worldwide. Regulatory approaches vary significantly, often lagging behind technological capabilities for data collection and sharing.
  • Exploitation of Vulnerable Consumers: Payday lending and similar high-interest, short-term loan industries often face criticism globally for targeting financially distressed individuals. The lead generation aspect, as allegedly practiced by ITMedia, adds another layer where vulnerable consumers seeking help are exposed to broader data exploitation and potentially predatory marketing.
  • Regulatory Arbitrage: The use of numerous LLCs, including some registered in different states (Nevada, Utah) or organized under tribal law, while operating from a principal place of business in California, can sometimes be indicative of attempts to find favorable legal or regulatory environments, a common tactic for businesses operating across jurisdictions in a globalized capitalist economy.

Systemic Commentary: The ITMedia case is not an isolated incident but reflects broader systemic issues within global capitalism, particularly concerning data privacy, consumer protection in online financial services, and the challenges of regulating complex corporate structures operating across borders or legal jurisdictions. The drive for profit in under-regulated digital markets often leads to similar patterns of consumer data exploitation worldwide.

Corporate Accountability Fails the Public: Knowing Violations?

The FTC’s complaint explicitly seeks civil penalties for knowing violations of the FCRA. This implies the agency believes ITMedia and the named individuals were not merely negligent but understood their obligations under the law and failed to meet them.

  • Awareness of FCRA: The complaint asserts that since at least 2013, Defendants knew the FCRA’s requirements, including the limits on permissible purposes for consumer reports and the illegality of using procured credit scores for purposes other than those certified!
  • Ignoring Industry Warnings: Awareness that claiming “no credit check” loans was misleading was allegedly present within their own trade organization since 2012.
  • Individual Involvement: Specific individuals are alleged to have formulated, directed, controlled, or participated in the practices. This includes reviewing representations, negotiating data sale contracts, implementing lead distribution policies, approving buyers (including non-lenders), procuring and using credit scores for marketing, and executing contracts enabling the alleged misconduct. Two individuals, Hancock and Kaufusi, are accused of intentionally avoiding knowledge while being aware it was highly probable that ITMedia was engaged in unlawful conduct in their names
  • Lack of Meaningful Safeguards: Despite written policies, the alleged lack of actual procedures to verify buyer legitimacy, monitor data use, or ensure data security suggests a potential disregard for substantive compliance.

Systemic Commentary: Cases like this often highlight failures in corporate accountability mechanisms. Even if violations are found, penalties may be seen as a cost of doing business rather than a deterrent. Settlements often occur without admission of wrongdoing, and holding individual executives personally liable can be challenging. Under neoliberal frameworks emphasizing corporate self-governance, robust external enforcement is crucial, but often lacks resources or political will, allowing harmful practices to persist until significant legal action is taken. The FTC’s pursuit of civil penalties represents an attempt to impose meaningful consequences.

Pathways for Reform & Consumer Advocacy

The alleged misconduct by ITMedia points to several areas where reforms could strengthen consumer protection:

  • Strengthened Data Broker Regulation: Implement stricter regulations for all entities buying and selling consumer data, requiring clear disclosures, purpose limitations, mandatory security standards, and regular audits. Enhance enforcement of existing laws like the FCRA.
  • Clear Consent Standards: Mandate clear, affirmative, and specific consent for data sharing, particularly sensitive financial data. Prohibit burying permissions in lengthy terms or relying on pre-checked boxes. Consent should be tied to the specific purpose understood by the consumer.
  • Enhanced FCRA Enforcement: Increase penalties for FCRA violations, particularly for impermissible use and resale of credit report information. Ensure regulators have resources to investigate complex data flows and hold both originating companies and downstream users accountable.
  • Increased Transparency: Require companies like ITMedia to clearly and prominently disclose all types of entities they share data with before the consumer submits information. Mandate easy-to-understand explanations of how data will be used.
  • Whistleblower Protection: Strengthen protections and incentives for employees within data brokers or lead generators to report illegal or unethical practices.
  • Consumer Education & Advocacy: Increase public awareness about the risks of online lead generators and empower consumer advocacy groups to monitor the industry and push for reforms.

Systemic Commentary: Addressing these issues requires moving beyond the neoliberal assumption that markets will self-regulate effectively. It necessitates proactive government intervention to set clear rules, enforce them vigorously, and prioritize consumer well-being over unchecked corporate profit-seeking in the data economy. Collective action and strong consumer advocacy are vital forces to counterbalance corporate influence and demand systemic change.

Modular Commentary: Legal Minimalism: Doing Just Enough to Stay Plausibly Legal

While the FTC alleges direct violations (deception, unfairness, FCRA breaches), elements of ITMedia’s alleged conduct also touch upon “legal minimalism.” This is the practice of adhering to the bare minimum letter of the law, or finding loopholes, while violating its spirit and intent.

  • Buried Disclosures: The use of fine print, separate terms pages, and hard-to-find “Third Parties” lists exemplifies this. ITMedia could technically claim disclosure occurred, even if the prominent marketing messages created a completely different, misleading impression. They complied with the form (having terms available somewhere) but allegedly not the intent (ensuring consumers actually understood where their data was going).
  • FCRA Pretext: Allegedly telling the credit reporting agency they needed scores for “pre-qualification” while actually using them for impermissible marketing, pricing, and filtering could be seen as using a legitimate-sounding purpose as cover for prohibited activities.

Systemic Commentary: Late-stage capitalism often rewards companies that master legal minimalism. Treating compliance as a checklist exercise or a cost center, rather than an ethical baseline, becomes normalized. The focus shifts from “is this right?” to “is this technically defensible?” This allows companies to operate in ways that cause significant harm while maintaining a veneer of legality, shifting the burden onto under-resourced regulators and harmed consumers to prove otherwise.

Modular Commentary: Profiting from Complexity: When Obscurity Shields Misconduct

The corporate structure described in the complaint provides a potential example of how complexity can shield misconduct.

  • Multiple Entities: The structure involves parent holding companies (XYZ LLC, 123 LLC), key operating subsidiaries (ITMedia Solutions, DEV.XYZ, TEAM.XYZ), and a dozen additional “ITMedia-Controlled LLCs” used for acquiring data, marketing, and collecting payments. These controlled LLCs had various registrations (Nevada, Utah, Ute Indian Tribe)!
  • Agency Relationships: Business was conducted by ITMedia as agent of these controlled LLC. Contracts were sometimes executed in the names of individuals (Hancock, Kaufusi) who owned sets of these LLCs but allegedly gave ITMedia “unqualified authority” to operate in their names. One individual, Grant Carpenter, allegedly managed ITMedia Solutions, managed Great LLC, and authorized business or executed agreements on behalf of Hancock and Kaufusi for numerous other LLCs!

Systemic Commentary: This intricate web of ownership, agency relationships, and varied registrations across jurisdictions is characteristic of how corporate opacity functions in late-stage capitalism. Complexity makes it harder for consumers, regulators, and even counterparties to track responsibility, follow money flows, and enforce accountability. It can diffuse liability, obscure beneficial ownership, and create challenges for legal action. While potentially established for legitimate reasons, such complexity often serves the strategic purpose of making the corporate entity less transparent and harder to pin down, shielding misconduct from easy scrutiny.

Modular Commentary: This Is the System Working as Intended

Viewing the ITMedia case through a critical lens, the alleged actions are not necessarily a “failure” of the system but a predictable outcome of a system prioritizing profit within a framework of minimal regulation and enforcement.

  • Profit Motive: The fundamental driver appears to be maximizing revenue from consumer data!
  • Exploiting Information Asymmetry: Consumers lacked knowledge of the complex lead generation market and relied on ITMedia’s prominent, allegedly misleading assurances. ITMedia allegedly leveraged this asymmetry.
  • Minimalist Compliance: Engaging in practices like buried disclosures suggests an approach focused on technical defensibility over genuine transparency.
  • Externalizing Risk: The risks of data misuse (identity theft, fraud) were allegedly passed onto consumers, while ITMedia profited from the data sales
  • Weak Oversight: The alleged ability to sell data widely without robust vetting and use credit scores impermissibly points to gaps in oversight or enforcement.

Systemic Commentary: Neoliberal logic argues that market forces and minimal regulation lead to efficiency and innovation. However, critics argue it predictably leads to exploitation when profit motives are unchecked, particularly in markets involving vulnerable consumers or complex products/services (like data flows). The ITMedia case, as alleged by the FTC, can be interpreted as the system functioning as expected under these conditions: generating profit by leveraging loopholes, information asymmetry, and externalizing costs onto individuals, until regulatory action intervenes. It’s not an aberration, but a reflection of the system’s inherent incentives.

Conclusion

The Federal Trade Commission’s legal complaint against ITMedia Solutions and its network of affiliates lays bare more than just alleged corporate misconduct; it exposes deep cracks in the systems meant to protect consumers in the digital age. By allegedly luring financially vulnerable individuals with false promises of access to “trusted lenders” and loans regardless of credit history, ITMedia is accused of betraying consumer trust on a massive scale.

The alleged subsequent actions – the indiscriminate selling of highly sensitive personal and financial data to a wide array of marketers, lead aggregators, and unknown entities, the impermissible use and resale of credit scores for marketing and profit, and the failure to implement meaningful data safeguards- paint a picture of a business model seemingly built on the exploitation of private information. The human cost involves exposure to identity theft, fraud, relentless marketing, and the violation of privacy, causing substantial injury that consumers could not reasonably avoid!

This case transcends individual corporate actions. It serves as a stark illustration of how deregulation, weak enforcement, complex corporate structures, and the relentless drive for profit under certain capitalist frameworks can combine to create environments where consumer harm becomes not just possible, but predictable. It highlights the urgent need for stronger regulations, transparent practices, and robust corporate accountability to ensure that the digital marketplace serves, rather than preys upon, the public.

Frivolous or Serious Lawsuit?

Based purely on the detailed allegations within the FTC’s complaint, this lawsuit appears to represent a serious legal grievance rather than a frivolous action. The complaint meticulously outlines specific alleged deceptive statements made across numerous websites, contrasts them with alleged actual business practices involving widespread data sales to non-lenders, details alleged violations of specific FCRA provisions regarding permissible purpose and resale procedures for credit scores, and describes allegedly unfair data handling practices risking significant consumer harm like identity theft!

The level of detail, citation of specific statutes, identification of numerous corporate entities and individuals allegedly involved, and the articulation of substantial consumer injury strongly suggest a well-documented case brought by a federal agency tasked with consumer protection. The claims reflect significant legal and ethical concerns regarding data privacy, truth in advertising, and fair business practices in the online lead generation industry.

itmedia_cacd_2_22cv73_1_complaintDownload

There is a press release on the FTC’s website where ITMedia Solutions agreed to pay a $1.5M penalty for doing this: https://www.ftc.gov/news-events/news/press-releases/2022/01/lead-generator-deceptively-solicited-loan-applications-millions-consumers-indiscriminately-shared

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