The CFPB continues to complicate matters for lead generators. In a recent circular, the agency asked, “Can operators of digital comparison-shopping tools or lead generators violate the Consumer Financial Protection Act (CFPA) by preferencing products or services based on financial or other benefits to the operator?” In short, yes. If you are looking for additional clarity, check out this FAQ with Troutman Amin, LLP’s latest addition, John Henson.