Limited Applicability of Consumer Financial Protection Act’s “Time or Space” Exception to Digital Marketers
The Consumer Financial Protection Bureau (CFPB) is issuing this interpretive rule to address digital marketing providers that commingle the targeting and delivery of advertisements to consumers, such as by using algorithmic models or other analytics, with the provision of advertising “time or space.” Digital marketing providers that are materially involved in the development of content strategy would not fall within the “time or space” exception as interpreted by the Bureau.