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Jonathan L. Pompan

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Jonathan Pompan is co-chair of the firm's Consumer Financial Services Practice Group and Consumer Financial Protection Bureau (CFPB) Task Force. Jonathan's practice focuses on providing comprehensive legal advice and regulatory advocacy to a broad spectrum of clients, such as nonbank financial products and services providers, advertisers and marketers, and trade and professional associations, before the CFPB, the Federal Trade Commission (FTC), state attorneys general, and regulatory agencies. At a time when government consumer protection agencies are stepping up their scrutiny, Jonathan develops strong and lasting relationships with clients by understanding their business objectives, helping them recognize opportunities and avoid legal pitfalls.

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The Consumer Financial Protection Bureau (“CFPB”) recently released a study of consumer financial services marketing, which found that it can be difficult for consumers to find objective information.  The study focuses on the size and scope of the financial information field.  The study was commissioned to understand the wide range of information sources consumers could be exposed to in making financial decisions.  The study’s results give an overall indication of the relative amounts spent in the U.S. on financial education and on the marketing of certain types of financial products.  We expect that the CFPB will use the results of the study to develop priorities in the areas of financial education, policymaking and supervision, and enforcement.

The key takeaways:

  • The results show that financial services companies spend about $17 billion each year on marketing, about $54 a person per year.  This excludes marketing of retirement products, college loans, and investment products.
  • By comparison, the report estimates the nation spends only about $670 million dollars on financial education, about $2 a person per year.  This excludes consumer purchased education.
  • The total amount spent annually by financial institutions and other financial service providers on consumer financial products and services, including both awareness advertising and direct marketing, is approximately $17 billion.

Financial services providers spend approximately $5.5 billion on awareness advertising annually.
Continue Reading Money Spent on Marketing Financial Products Beats Financial Education

Readers of this blog know that market testing can be one of the most efficient ways to gauge the viability of an advertising and marketing pitch.  Financial institutions can now take advantage of a program launched by the Consumer Financial Protection Bureau (“CFPB”) that permits companies to market test pre-approved disclosures about consumer financial products.

Under the CFPB’s Trial Disclosure Program and Information Collection Policy, companies can seek the CFPB’s approval to use a specific disclosure while being deemed to be in compliance with applicable federal disclosure requirements – at least by the CFPB. 
Continue Reading Trial Disclosure Program Announced by CFPB Allows In-Market Testing

The credit card market continues to be high on the Consumer Financial Protection Bureau’s hit list.  As noted in prior blog posts, the CFPB is focused intently on advertising and marketing of financial products and services.  Because large advertising dollars are spent on credit card marketing, card issuers need to proceed with caution.

So…

No one likes complaints, being blamed for not meeting expectations, or worse, but the fact is the FTC collects and reports on millions of complaints by consumers.  Last week the FTC issued its 2012 annual report of consumer complaints from its Consumer Sentinel Network, an online database used for tracking complaints.  The FTC received more…

Social media use will soon be scrutinized as part of exams of providers of consumer financial products and services by federal and state regulators.  On January 22, 2013, the Federal Financial Institutions Examination Council (“FFIEC”) released a notice and request for comment on proposed guidance on the applicability of consumer protection and compliance laws, regulations,…

Lately it seems like every aspect of advertising and marketing targeting the military is ripe for generating positive public relations in the name of consumer protection.  In a new and aggressive move, earlier this month, the Department of Veterans Affairs (“VA”) announced it had registered the term “GI Bill” as a trademark or brand with…

The Consumer Financial Protection Bureau (“CFPB”) and the Federal Trade Commission (“FTC”) have targeted mortgage advertising and marketing in a joint “sweep.”

Just prior to the Thanksgiving holiday, the CFPB and FTC announced they issued warning letters to mortgage lenders and mortgage brokers advising them to “clean up potentially misleading advertisements, particularly those targeted toward…

Pink_ribbon_cause_marketingLast week, the New York Attorney General (“NY AG”) released a much anticipated follow-up to its “Pink Ribbon” cause-marketing initiative. The guidance issued has far-reaching effects for both charities and companies engaged cause marketing efforts as the NY AG has often in the past has helped set enforcement trends nationwide.

As many will remember last…