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Re-intermediation: lead generators

Consider, for example, a person who googles "need rent money fast" or "can't pay rent."

Among the search results that Google returns, there may be ads that promise to help provide payday loans--ads designed to circumvent Google's policies against predatory financial advertising.

They're placed by companies called lead generators, and they work by collecting and distributing personal information about consumers online. So while Google says it bans ads that guarantee foreclosure prevention or promise short-term loans without conveying accurate loan terms, lead generators may direct consumers to a landing page where they're asked to input sensitive identifiable information.

Then, payday lenders buy that information from the lead generators and, in some cases, target those consumers--online, via phone, and by mail--for the very sorts of short-term loans that Google prohibits.

See also Led Astray: Online Lead Generation and Payday Loans, October 2015.

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