This time they are sending out the credit card consolidation loan offer in an artificial express envelope.
As you read the offer sent to this consumer, remember that White Mountain Partners is not a lender. Would you be able to tell that from the letter they are sending out?
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The White Mountain Partners website says, “White Mountain Partners is not an agent of you or any lender. White Mountain Partners services are only administrative. White Mountain Partners is a paid marketing lead generator.” – Source
When the mailer uses phrases like:
- “Pre-Approved Debt Consolidation Loan Documents”
- “This is a valid offer. You are pre-approved for an unsecured low interest rate Debt Consolidation Loan for your unsecured high-interest credit card debt. White Mountain Partners works with the credit bureau and has identified you as someone who may benefit from our debt consolidation loan product.”
- “You have been pre-approved for a credit card debt consolidation loan of up to $50,000.”
- “CONSOLIDATION LOAN ACCEPTANCE INFORMATION AND PROCEDURE”
When White Mountain Partners says, “White Mountain Partners works with the credit bureau and has identified you as someone who may benefit from our debt consolidation loan product,” it makes me wonder if they are not running afoul of the CFPB guidance by using information from credit reports to market debt relief services is off-limits. Of course, they could be purchasing mailing lists and not accessing credit report information, but that does not appear to be clear to me.
If you want more information on that CFPB stance, read this.
At What Point is an Offer Unfair and Deceptive?
The string of lead generation company names coming out of Bloomfield Hills, Michigan, makes me wonder at what point does sending pre-approved loan advertisements when you are not a lender becomes unfair and deceptive.
If an unsophisticated consumer is confused by these mailers, doesn’t that create a problem?
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