This COMPLY Podcast episode is part 1 of a discussion between John Zanzarella, PerformLine’s SVP of Sales, Jonathan Pompan, Partner at Venable LLP, and Brian Serafin, Counsel at Weiner Brodsky Kider, as they take a deep dive into recent regulatory activity around UDAAP and deceptive advertising and best practices for getting ahead of risk.
They discuss:
- Recent activity from the CFPB and FTC around UDAAP and deceptive advertising
- Expectations for the impact of the Supreme Court’s ruling to uphold the CFPB’s constitutionality
- Why product, marketing, and compliance teams need to collaborate for success
Show Notes:
- Top UDAAP Compliance Issues Across Marketing Content: https://content.performline.com/report/the-top-udaap-compliance-issues-across-published-content
- UDAAP and Deceptive Advertising: Expert Insights & Best Practices: https://www.performline.com/blog-post/udaap-and-deceptive-advertising-expert-insights-and-best-practices/
- The Ultimate UDAAP Compliance Checklist: https://content.performline.com/checklist/udaap-marketing-compliance-consumer-finance
- Connect with John: https://www.linkedin.com/in/johnzanzarella/
- Connect with Jonathan: https://www.linkedin.com/in/jonathan-pompan-43535935/
- Connect with Brian: https://www.linkedin.com/in/brian-serafin-23297620/
- Connect with Gianna: https://www.linkedin.com/in/gianna-kennedy/
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About COMPLY: The Marketing Compliance Podcast
The state of marketing compliance and regulation is evolving faster than ever, especially for those in the consumer finance space. On the COMPLY Podcast, we sit down with the biggest names in marketing, compliance, regulations, and innovation as they share their playbooks to help you take your compliance practice to the next level.
Episode Transcript:
Gianna:
Hey there COMPLY podcast listeners and welcome to this week’s episode. This episode is part 1 of a discussion between John Zanzarella, PerformLine’s SVP of Sales, Jonathan Pompan, Partner at Venable LLP, and Brian Serafin, Counsel at Weiner Brodsky Kider.
Listen as they discuss:
- Recent activity from the CFPB and FTC around UDAAP and deceptive advertising
- Expectations for the impact of the Supreme Court’s ruling to uphold the CFPB’s constitutionality
- Why product, marketing, and compliance teams need to collaborate for success
John:
Hey, everyone, and welcome to a COMPLY webinar sponsored by PerformLine. My name is John, and I run the sales team here at PerformLine. We’re really excited about today’s topic. It’s obviously one that’s near and dear to a lot of our clients and the compliance ecosystem, which is particularly around UDAAP and deceptive advertising, and the cost of misleading marketing materials.
For all of you on the call, you know that the regulatory agencies this year, in particular, have really been placing a greater emphasis on deceptive advertising practices under UDAAP. That has caused a lot of conversation within the industry around best practices and how your companies can prepare for what the next six months of the year looks like. With us today, we have two experts on this area. I’m gonna have them introduce themselves. We’re really excited to speak. We’ll spend the next 50 minutes or so with you all to talk about this topic. Brian, why don’t you kick it off with an introduction.
Brian:
Thanks, John. Sure, my name is Brian Serafin. I’m counsel with the law firm Weiner Brodsky Kider. I work out of Washington, DC. My practice mainly focuses on the financial services space, particularly mortgage companies, banks, and some settlement service providers. We do a mix of litigation and regulatory compliance. So again, I’m really glad to be on this. We do a lot of work involving the CFPB, so UDAAP is certainly always on our and our customers’ minds. Thanks for having us here.
John:
Yeah, we’re happy to have you, Brian. And Jonathan, why don’t you go next.
Jonathan:
John, thank you. And it’s a pleasure to be here and support COMPLY, PerformLine, and the community that you’re building and have continued to build for years now. My name is Jonathan Pompan. I am a partner at the law firm Venable in our Washington, DC office. I chair our consumer financial services practice. Our practice and our group ranges all the way from advertising and marketing of consumer financial products and services by service providers and the direct providers themselves, all the way through from origination, lending, and payments to collections and debt buying. So it’s a broad range of areas in which we focus, and the communities in which we’re involved, as well as a broad range of services ranging from regulatory day-to-day compliance all the way through litigation, mergers and acquisitions, and everything in between.
John:
Awesome, great. Thank you, Jonathan. Good to see you again. Jonathan has been a past COMPLY speaker at both our in-person events and our webinars. Yeah, I see the record there in the background. It’s great to have you on again. Thank you. Brian, you mentioned it earlier.
We’ll start with the CFPB. I’ll pass this over to you. Earlier in the year, the Bureau published a circular discussing deceptive marketing practices specifically around the speed or cost of sending a remittance transfer. They cited terms that are very familiar to us on the call, at least like “free,” “no fee,” and “instant” as particular compliance issues or UDAAP issues. Even more recently, we saw commentary around a fintech for false advertising, marketing loans as no interest and having 0% APR, which proved not to be true. Is there anything in this that was surprising to you, and for your companies that you’re talking to and advising? What are some of the recommendations you’re making for how they can, you know, maybe change what their strategy is regarding some of the increased actions from the CFPB?
Brian:
Sure. So particularly for cases like this, it tends to be an issue of when you say there’s no fee or no interest. What are you really talking about? In the eyes of the CFPB, they tend to basically view anything paid by the consumer as either a fee or interest, as the case may be, a fee or finance charge. So just because your company might call it a donation, or a tip, or a convenience charge, or something like that, just because you don’t literally use the word “fee” or you don’t literally define something as a finance charge doesn’t mean the CFPB is going to see it that way. I think in the particular examples you gave, that was the big issue. Just to kind of give an example, you mentioned the one in remittance fees. It tended to be that these companies would say there’s no fees or it’s free. But in fact, there might be something like there are taxes or currency and conversion exchange fees, or sometimes there’d be a situation where the person sending the money didn’t have to pay a fee, but the recipient had to pay a fee when they picked up the money. So again, you have to be very careful about what you call free. Just because you might not literally be using the word fee for this type of charge going to the consumer, the recipient doesn’t mean that the government’s not going to see it that way. They’re not letting terminology get in the way of going after the general concept of what the consumer is paying.
John:
Yes, that’s interesting. Jonathan, moving over to you. That concept, like, if you’re a fintech today and you’re building out a set of products around a definition that you have for those products, whether it’s a zero or no interest product, how do you start to take into consideration the compliance perspective that, hey, there’s this different grading rubric that we need to look at that’s coming from the CFPB, and we actually need to include all these words in our, you know, marketing compliance checklist? How do you have that conversation with the compliance team?
Jonathan:
Well, John, the conversation is deeply important and for different organizations, it is going to take place in different ways. For some organizations, it may be that the compliance staff is embedded with the product development and the marketing development from the get-go. For others, for instance, it could happen far later in the process, but regardless, the conversation has to take place because the CFPB’s circular and its actions serve as a critical reminder to organizations about the importance of transparency and accuracy in their marketing practices. While there is a minimum level of transparency and accuracy that’s needed, it’s important to recognize that the Bureau is without question raising the bar, as you indicated a moment ago. The CFPB’s circular and enforcement actions highlight several key points for organizations to consider, and I think these all need to be part of the conversation.
I think, first off, accuracy in the marketing claims. Organizations have to ensure that the marketing claims are truthful and not misleading. Terms like free, no fee, and instant have to reflect actual experiences that customers, or in this case, applicants, depending on where we’re at in the cycle, have to be considered, and any deviation that could take place has to be factored in, and how the claim is put together. It’s low-hanging fruit for an examiner or in an investigation, whether it’s by a customer, partner, or a government agency. So it’s critically important. I’d also note that clear and conspicuous disclosures are necessary. A disclosure or a disclaimer can’t correct the misleading claim, but it’s essential to provide clear and conspicuous disclosures about fees, rates, and material terms. So that’s the flip side of saying no fee. Well, if there actually is a fee, what is it? What’s it based on? What’s material prior to purchase or prior to the selection of a particular financial product or service by a consumer, and they have to be easy to understand. Those disclosures can’t be hidden or buried. Of course, having the conversation as routinely and regularly as possible by compliance departments is critical.
John:
So, Jonathan, I’ll just lean into that for a second. So you’re talking about having the conversation with compliance departments being critical. We’re talking about companies making sure that they have the appropriate disclosures and language on their own and operated websites and their marketing materials. What is the advice you give to companies who are working with third parties, let’s say, on the customer acquisition side of things? So if they’re working with influencers, if they’re working with networks or affiliates to help market their products, and obviously, by virtue of that, share their marketing materials. How are you telling them to treat those relationships and make sure that that message is being appropriately monitored?
Jonathan:
Well, at least from the CFPB’s perspective or the Federal Trade Commission’s perspective, for example, the standard operating procedure of an organization should be that any claims, advertising, marketing practices that are engaged in by third-party vendors for advertising and marketing purposes are essentially the same as if they’re being made by the company itself. Now, that may not always be necessarily exactly how it will unfold, but at least from an operating perspective, from a compliance oversight perspective. That’s what certainly one would want to do. By doing so, that means, first and foremost, knowing who those vendors are, understanding what their activities are, and factoring that into the compliance program. It’s not enough to monitor your own advertising and marketing if it turns out that 50% or more of the advertising and marketing is happening by third parties. Those third parties are going to need to be reviewed, examined, monitored, and in some cases, if not disciplined, opted out from as vendors. If there are issues that arise, it’s important that it happens on a continuous and regular basis. Doing it at one point in time and then dropping your guard doesn’t help.
John:
Brian, anything you want to add to that?
Brian:
Yeah. I think those are really good points. Part of the process is that you’re going to have to educate your third-party vendors. If you’re working with a large established company, maybe less so. But if you’re looking at a single person who’s making videos online or something like that as an influencer, they’re probably not going to have a huge compliance background or a huge compliance department working with them. So in some cases, you really need to explain to them, “Here are the processes we use. Here’s why you need to use them so that we can work together.” Again, it’s part of understanding your vendor, understanding their own level of either compliance knowledge or how sophisticated they are, and also just monitoring over time. Just because on day one they’re doing everything by the book, you need to be sure that by day 50 or day 100 or further down the line, they’re still sticking to all these requirements.
Jonathan:
And John, Brian mentioned a good point. You have to understand and do a little bit of background. The flip side would be true also for vendors. From the vendor perspective, vendors have to understand what it is that they’re advertising and marketing, and particularly if they’re doing lead generation activity as a third party, possibly sharing those leads and the inquiries with multiple organizations. The important thing will be to understand what’s the lowest common denominator and not to necessarily tailor the advertising and marketing to one particular product or service or product characteristics if, in fact, that inquiry is supposed to be essentially potentially a one-size-fits-all. Practices with respect to lead generation and the funnel and pre-qualification stuff vary widely amongst different subsets of the financial services sector. They also continue to evolve because of the changes in the law, including, for instance, the Telephone Consumer Protection Act rulemaking that the FCC recently did. But that all being said, generic advertising will be safer than specific advertising if, in fact, you can’t guarantee with any degree of certainty that an inquiry is actually going to be placed at a particular company with the product characteristics of the services that you were advertising in the first place. So for vendors, it’s as much about knowing how far and how specific they can advertise and market, what claims they can make, but it may not be entirely the same calculus as if they were the provider of the service themselves.
John:
Yeah, that makes a lot of sense. I think one of the common threads that you’ve touched upon, even with the first few answers in this conversation, is that compliance really needs to have a seat at the table in a lot of these conversations early on. It sounds like on the product side, and certainly on the marketing side. But even if it’s through marketing, some sort of relationship or influence over those larger third-party partners who may be driving a certain percentage of that customer acquisition before we move off the CFPB. I do want to mention that there was the pending Supreme Court decision that is now behind us. It was ruled in favor of the Bureau. So now that that narrative isn’t really at the forefront anymore, do you expect any sort of change in CFPB behavior with regards to UDAAP? And how do you think they plan to continue driving sort of UDAAP as a regulation?
Brian:
I’ll say, you know, it was interesting. The decision you’re talking about found their funding structure to be constitutional. That was issued on May 16th, and on May 17th, they filed a new complaint against a fintech company about the issues we’re talking about—saying something is free or has no interest rate or no APR. It seems like they were almost holding that in the can, waiting for the day that they got a ruling in their favor, and then they were ready to go. I think that just emphasizes that they’re not backing down. If anything, this sort of direct thing that might have been a little bit of a drag on them, giving them some hesitation to proceed over the last year or so, now it’s gone. That restraint that has been holding them back because they weren’t quite sure what they could do in terms of funding is no longer there. I think, to some extent, certainly under the current director, and probably for his beginning, the CFPB has definitely been an organization that pushes the envelope, takes very broad or expansive views of the laws it’s enforcing, and goes after business as usual. Just because people have always done it that way, or just because everybody does it, does not mean it’s okay. I think we’re going to continue to see very aggressive enforcement action and very close scrutiny of practices that people have historically thought were okay. Certainly, with the upcoming election, they’re going to have a lot of incentive to generate good headlines for the agency and, by extension, the administration. So, they’re certainly not going anywhere.
John:
Jonathan, you want to add anything to that?
Jonathan:
Yeah, no question. The CFPB is not going anywhere, especially in the short term. Certainly, in the longer term, there is the question of what will happen if there’s a change in administration next January. But that’s a long way away. In the meantime, the Supreme Court’s decision affirming the constitutionality of the CFPB is a significant development. It solidifies the Bureau’s authority and mandate to regulate and enforce the consumer protection laws. We can reasonably anticipate an increase in CFPB activity, particularly around UDAAP. I think we can expect increased regulatory activity. Now there is a fairly short window, and depending on when someone is watching this webinar, it may have already passed. There is a short window for the CFPB to get rulemakings out the door prior to what can happen with the Congressional Review Act. That’s a bit nuanced, but it essentially creates a veto opportunity depending on what happens politically with the government. But in the meantime, with its increased authority under UDAAP and its solidified Supreme Court standing from a constitutional standpoint, it’s likely that the CFPB is going to increase its regulatory rulemaking output. Now, that’s not everything. But that’s one thing.
The next thing is I think we’re going to see a step up in public regulatory and enforcement actions. This may include more frequent issuance of circulars, proposed rules, and other things, using UDAAP as the justification. These regulatory documents, such as circulars and proposed rules, signal to the community where the CFPB views UDAAP on a policy level. It sets requirements and market conditions for conduct. You’re also going to see enhanced enforcement activity. The CFPB is going to continue and possibly intensify its use of enforcement actions and consent orders using UDAAP. There are a number of non-public confidential investigations taking place. These have been ongoing now for a year or more, and look for them to slowly but rapidly come to a close publicly in the next several months, simply because, again, the Bureau is up against a potential change in administration. As a result of that, they’ll look to wrap up as much as possible prior to January, depending on what happens in November. Enforcement actions serve as a powerful tool for the Bureau to determine misconduct, penalize violators, and provide redress to consumers. But it’s not the only tool it has. I think what’s important is that there are also regulations through exams. That’s a huge place where we’re seeing UDAAP being used as a justification for imposing policy conditions that the Bureau believes fall under UDAAP, but haven’t necessarily been precedential or historically viewed as UDAAP. It’s through the exam process, and that confidential nonpublic process, where compliance is typically deeply involved, and it raises the stakes for exams from being routine and regular to being something that actually could be a seismic existential threat to a company and really put a company’s back against the wall. So, John, I think one of the sleepers here, with respect to CFPB activity, is the use of UDAAP in exams. Again, companies are being looked at one-on-one, and as a result, they don’t necessarily have all the recourse and due process that they would have if the action taken by the Bureau was public. It’s a two-edged sword because oftentimes companies would prefer to deal with issues or potential issues and allegations on a non-public basis. But in some cases, some companies might ultimately have no choice but to litigate some cases.
Brian:
Just to add one other thing about your comments on the examination process: obviously, exams themselves for individual companies are confidential, so we’re not going to hear about them publicly. But a couple of times a year, the CFPB publishes something called Supervisory Highlights. It’s basically a list of specific examples of violations they found in exams, all on a no-names basis. It’s actually one of the great tools to see what particular trends they’re looking at, what new violations they found, and in some cases, what new legal theories they’re pushing. Sometimes in these Supervisory Highlights, you’ll see something like, “That doesn’t sound like any violation I’ve ever heard of before,” and then months or a year later, you’ll suddenly start seeing them bring public actions based on the same theory. So it’s one of the ways they telegraph a little bit in advance where they’re going. For those of you who, thankfully or luckily, are not subject to one of their exams at the moment, you can at least get this little window into what they’re looking at through the exam process.
Jonathan:
Yeah, I think, Brian, with the exam process, one of the things that’s really interesting too, we’re seeing this in our practice, is that while we’re now over a decade into the CFPB, there are some organizations that, either because of an increase in size or change in scope and focus by the CFPB, are undergoing in some cases their first examination. That’s where we’re starting to see the CFPB push novel theories and overreach with respect to UDAAP, taking things from circulars and then imposing them into organizations from the get-go. In some cases, these are companies that are of first impression for the Bureau. The Bureau hadn’t previously looked at them, either again, because of size or because, for instance, their service providers to financial institutions or other ways that the CFPB can get to larger players and cover a large swath of industry and sectors without actually going after or looking at each and every organization, financial institution. In some cases, the CFPB doesn’t even have jurisdiction over every financial institution, but it may over a service provider. As a result, it opens the door for the CFPB to impose its circulars, impose its findings and prior exams on organizations, and then oftentimes companies are faced with a situation where either they can push back. But again, they’re new. The relationship with the CFPB may be new. They may be untested and inexperienced in how to deal with the Bureau on that level, or at the same time, the Bureau may be looking to flex its muscles.
Brian:
Obviously, from the Bureau’s perspective, it’s often a lot easier to go after a much smaller company than a larger one. If they can convince a smaller company to agree to a consent order, they still create this precedent in the eyes of the market and the other players in the industry. Here’s something we’re going after. Here’s how we interpret this, and if you don’t want to face the same problem, you need to change your practices.
Jonathan:
That’s absolutely right. Sometimes smaller companies aren’t necessarily small enough from a standpoint of revenue. It may be that they have fewer products and services. If you’re a one-trick pony and the company offers, say, a software product or does advertising and marketing for one particular sector, and that’s it, with no diversification, no additional products and services, there’s very little room to spread out that regulatory risk and the potential financial hit as well as the hit to reputation and business if you only have one product or service. As a result, we see that come into play too. Regardless, the Bureau is using an ends-justify-the-means approach, and UDAAP is the weapon.
John:
So with that being said, it sounds like it may be a daunting task for compliance professionals over the next 6 to 12 months. Obviously, we’ll see how the election goes. If you were to put yourself now in their seats, you are that smaller company or mid-size company, and you may be experiencing your first CFPB audit, or you’re going through this next cycle with them. What are the recommendations you would make to them? I’m going to ask it two ways. What are the recommendations you can make to them? What they can do today without adding anything else? But then, if they were going to go and ask for additional resources, maybe anything you could share with them as far as justification. I think you did a good job of explaining what could be coming, but anything to help them gain, you know, maybe it’s more dollars or people to help keep up with some of the changing compliance priorities.
Jonathan:
Sure, John. It’s a terrific question because it is critical for organizations to plan ahead. As we’ve talked about regulation through exams, in some cases, first exams. If you haven’t had one, you still could, particularly in this administration. There’s always the potential for investigation, third-party oversight, and vendor oversight. There are any number of ways that an organization can be tested. I think in response to that, organizations benefit from a multi-pronged approach. It is additional resources from a people’s standpoint, but also technology as well as scope. Just like the CFPB uses a combination of tools. For instance, regulatory exams, circulars, rulemaking, guidance to consumers, speeches from the bully pulpit, and so on, as well as the consumer complaint database and other tools to identify potential areas for risk. Companies need to do the same thing. So I think it’s a combination of products, services, and people. I would highlight a couple. First and foremost, somebody to be in a position to track and socialize the developments that are happening. That’s not just the developments that are happening that are plain as day, not just the ones that are enforcement actions after the fact. But focusing on emerging issues and how they intersect with the products and services of a business you’re working with. Given the dynamic nature of the financial services industry and technology, the CFPB, FTC, and other government agencies have a lot of different pieces that need to be put together constantly. Sometimes there’s a need to think outside the box. That’s not traditionally the core role of compliance, but in this dynamic situation, it’s necessary. The use of technology is no longer optional. It’s a necessity.
Brian:
Yeah, no, I mean, those are all great points. Especially if you’re a company that’s new to this compliance space, part of the task is building up a solid compliance management system. It’s getting your processes in place, getting everybody trained on them, making sure that you’re actually monitoring to make sure those processes are being implemented the way they’re supposed to be. Are you tracking consumer complaints? Are you checking updates? The language of the UDAAP statute hasn’t changed since it was passed in 2010. It’s been about 14 years now, but just because the language of the statute hasn’t changed doesn’t mean the way it’s interpreted hasn’t changed. So you have to track these changes, not just at a high level of whether the statutory language has changed, but how the agency is actually applying it, how other companies are reacting to this. It’s all part of building a really well-integrated compliance management system and making sure that you’re ready to adapt to these changes as they come. The point on technology is also critical. We’ve had clients who sometimes update everything in Excel spreadsheets. Unfortunately, at the pace of business and the size of companies, you really can’t have an employee doing that. Things need to be more automated. This needs to be tracked electronically. Reminders need to be sent out electronically. If it’s all just one person trying to juggle everything, it can get too overwhelming. Technology is becoming even more critical.
John:
It’s interesting. I’m just listening to you talk here, and as a person who has been on the marketing side for most of my career, the concept of having to track the changing interpretation of 14-year-old rules shows how problematic it can be both on the marketing side and the compliance side, which needs to keep up with that ever-changing interpretation. That’s why webinars like this are really important. Getting a chance to share these concepts from both of your companies helps keep the audience on top of those changing interpretations.
So, shifting from the CFPB for a second, but staying on more or less the same topic, the FTC over the last six months has also been very active with four separate enforcement actions against companies for deceptively using the terms we just discussed—things like “free” and “instant”—in their marketing materials. I think you did a good job of highlighting why those terms are problematic. Are you seeing anything different from either the enforcement actions or just the language from the FTC when it comes to UDAAP, maybe different from the CFPB?
Jonathan:
Sure, John. I think just to distinguish, and most listeners and viewers are going to understand this intuitively, the difference between the UDAAP of the CFPB and the FTC is the second “A”—abusive. At the CFPB, it’s not enough to be in compliance where something is not unfair or not deceptive. It also has to be not abusive. Abusive can run not just to the facial advertising and marketing, but also to the core product or service all the way through the lifecycle. It gives the CFPB a much more expansive ability to look at a product or service, or an entire company or business model, than the FTC has historically looked at. The FTC has historically looked at deception and unfairness through much more of a facial lens. In this case, the terms that you’re highlighting, like “free” and “instant,” are particularly problematic in financial services advertising for a number of reasons. But they’re not inherently, necessarily per se violative of any statutes, regulations, or guidance. It’s just that they often aren’t compatible with the financial product or service with which they’re being paired. That’s run-of-the-mill, one-on-one FTC Section 5 UDAAP.
Terms like “free” and “instant” have some meaning to consumers and create expectations. When that doesn’t match the product or service that’s ultimately going to be provided, there’s an issue. Depending on what it is, it can be a material issue for an organization. When consumers see terms like “free” and “instant,” they have specific expectations. “Free” implies that there are no costs whatsoever associated with the product or service, and “instant” suggests immediate access to the service or processing. In financial services, where transactions and fees can be complex, those simple terms can often have a halo effect over an entire product or service, and how they’re going to be viewed. The complexity of financial products and services makes it so that when the FTC is looking at advertising and marketing, this is true also for other regulators as well, they often come with much more intricacy. They’re matching up the claims being made with the intricacy of the product and service, as well as the footprint, for instance, the geography in which the product or service is going to be offered, or the demographics to which the product or service is going to be offered. An unexpected result or an exclusion can lead to, in some cases, terms that the FTC has identified as problematic. I think it’s important to recognize that with financial products and services, the complexity and consumer expectation can make it difficult to use some basic advertising terms, depending on what it is that’s happening and how they’re going to be used in the marketplace.
Brian:
Just one thing to add, this goes to the idea that you really need to have all these different departments of the company well integrated. The people who design the product, the marketing department, and the compliance team all really have to be talking with each other so that they all understand each person’s roles. Your marketing team really has to understand how this product works in practice, as the consumer experiences it, so they can make appropriate claims about what it does or how it’s paid for. Just because the consumer might not be paying a fee at one phase of the transaction doesn’t mean there might not be some other charge that occurs later. It’s about having everyone on the same page. What’s being answered? What are the compliance requirements? Instead of having everyone be siloed, with the product going from one department to another without much discussion.
John:
It feels like one of those things, Brian. It’s like the best time to get those departments talking to each other was when you started. The next best time is right after you watch this webinar. So, if you need to do that, get those groups together and start doing it.
Gianna:
Thanks for listening to this week’s podcast! We have a few resources around UDAAP and deceptive advertising that we’ll link in today’s show notes. As always for the latest content on all things marketing compliance you can head to performline.com/resources. And for the most up-to-date pieces of industry news, events, and content be sure to follow PerformLine on LinkedIn. Thanks again for listening and we’ll see you next time!
Rhonda McGill 
