Affiliate marketers in the financial services industry face a new landscape following the Consumer Financial Protection Bureau (CFPB) issuing a new circular of guidance on “preferencing and steering practices” by digital intermediaries or affiliates.
The guidance, outlined in Consumer Financial Protection Circular 2024-01, clarifies that prioritising financial products based on payments received by comparison sites, rather than on what’s best for consumers, is considered illegal.
This practice, known as “steering,” violates the CFPB’s Abusive Acts or Practices rule.
While the ruling doesn’t ban affiliate marketing entirely, it significantly impacts how comparison sites can utilise their paid partnerships.
Prior to this ruling, comparison sites often used affiliate marketing to highlight specific products, sometimes burying better options for consumers deeper within their results. This “curated” approach steered consumers towards products that were more profitable for the comparison site, not necessarily the best fit for the individual’s needs.
The CFPB’s new guidance demands a shift towards a more neutral presentation. This could effectively change the internet landscape for financial product searches, potentially turning comparison sites into something akin to an online yellow pages.
The full impact of the CFPB’s guidance is yet to be seen, but it undoubtedly represents a significant change for affiliate marketers in the financial services sector.
Adapting to the new regulations while maintaining consumer trust and generating revenue will be the key challenge for businesses in this evolving landscape. Read the full circular and additional analysis on the circular that was released last week.