On April 21, the CFPB filed two complaints against the individual owners of an online lead aggregator for their alleged involvement in the company’s practice of reselling consumers’ sensitive personal data to lenders and debt collectors without assessing the sources of this data, a practice the CFPB claims exposed consumers to the possibility that their personal data could be used for illegal purposes. In December 2015, the CFPB filed a complaint against the California-based company for allegedly buying and selling personal information from payday and installment loan applications without “properly vetting buyers and sellers.” The CFPB’s December complaint further alleged that, among other things, the company (i) knew or should have known that the lead generators in its network used false or misleading statements to obtain consumer information; and (ii) connected consumers with lenders that offered less favorable loan terms than were otherwise available, did not comply with state usury limits or claimed they were exempt from state regulation and jurisdiction. The most recently filed complaints charge the two individual owners with, among other things, “knowingly or recklessly provid[ing] substantial assistance to [the company] in its unfair and abusive acts and practices, in violation of [the Dodd-Frank Act].” This assistance allegedly enabled the company’s lead generators “to attract consumers with misleading statements and [take] unreasonable advantage of consumers’ lack of understanding of the material risks, costs, or conditions of the loan products for which they [applied].” The CFPB’s complaints against the individual owners seek monetary and injunctive relief, as well as civil money penalties.