Report: Swipe Right

DOI: 10.13140/RG.2.2.35869.01761

This report is also available as a PDF.

Executive Summary

Through Swipe Right, the Southwest Public Policy Institute explores the transformative role of comparison shopping tools, digital intermediaries, and lead generators—ubiquitous engines behind nearly every consumer product and service in America—empowering individuals with unprecedented access to financial services and countless other offerings online. With their faster, more streamlined, one-stop, user-friendly processes, these tools significantly improve the consumer experience compared to traditional direct lender applications. They save time and effort, and improve access to suitable products, fostering a more competitive and transparent marketplace. As regulatory challenges loom, it’s crucial to recognize and preserve these market-driven innovations.

Introduction

Imagine a recently divorced parent of three, navigating the emotional and financial aftermath of separation. With new strains on your finances, such as additional rent, travel, and legal costs, you need short-term liquidity, a small line of credit to get through the month. This is not a far-fetched scenario but a reality for many Americans. It was Patrick’s reality.

In the weeks following his divorce, he applied for several different credit-repair credit cards directly with major banks. Despite a solid, albeit strained, financial history, every application was either rejected or incomplete. What made them incomplete? The process was time-consuming and disheartening, leaving him without the much-needed financial cushion he sought. After several weeks of receiving incomplete application notifications, Patrick knew there had to be a more efficient and simplified way to get approved.

Desperate, he turned to a comparison shopping tool—Credit Karma. Unlike his previous experiences, this platform offered a streamlined application process, quickly matching him with a credit card that guaranteed approval. Within minutes, he had secured a card, providing the liquidity he needed.

This experience is not unique; it highlights the critical role of comparison shopping tools in today’s financial marketplace. However, these tools have been under threat. Before his firing in January of this year, Former Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra oversaw the implementation of arbitrary rules that targeted the lead generation and comparison shopping business model.

“Technology advances are nothing new to the financial world; inventions such as the ATM and the credit card led to significant improvements in consumer welfare.”

Senator Mike Crapo

The Federal Communications Commission’s (FCC) now defunct one-to-one consent rule added to this regulatory pressure, which attempted to stifle communication between consumers and service providers. This rule required explicit consumer consent before lead generators or comparison shopping tools could share data. While aimed at privacy protection, this shift attempted to increase friction in a process designed for consumer ease and transparency.

This regulatory overreach jeopardizes consumer access to financial services and has broader implications across various markets, from travel and airfare to babysitters and plumbers. When it comes to financial matchmaking, the question arises: would you rather trust innovative tools such as LendingTree, Credit Karma, and NerdWallet that allow you to analyze the pros and cons of financial products intimately better than Tinder, or would you rather be at the mercy of a government bureaucrat who dictates who you can bank with?

Swipe Right – or Left

In 2024, the CFPB issued a pivotal circular targeting lead generation and comparison-shopping tools, expanding its regulatory reach significantly. This move reflects the agency’s growing concern over how these platforms, which compare credit cards, loans, and even services like travel bookings, may prioritize financial gain over consumer interest. The sweeping scope of the CFPB’s directive is not just confined to financial services; it threatens industries far beyond, including platforms like Google and Expedia, which generate revenue through advertising and lead generation.

The lead generation landscape is diverse, consisting of marketplace-style models (like Credit Karma, NerdWallet, WalletHub, and LendingTree) and more intricate ping-post or ping-tree systems commonly used in subprime lending. While both aim to provide consumers access to credit, they operate differently. Marketplace-style platforms, such as Credit Karma, offer users various loan options based on their credit profile, allowing them to select offers that best suit their needs. In contrast, the “ping-tree” approach is more like saying, “I need a loan; who wants to date me?” Here, a consumer’s application is shared across a network of lenders who bid in real time for the lead, often resulting in multiple loan offers. While both methods provide choices, the presentation and process differ.

“Working families have been ripped off by abusive bank fees and practices in the past, and the CFPB’s rule is about protecting hardworking families, not charging them more.”

Senator Chuck Schumer

These differences don’t imply one method is better than the other. The marketplace model offers consumers a broader, more transparent view of available loans. In contrast, the ping-tree model provides multiple potential offers for those who may not qualify for mainstream credit. Importantly, neither model forces consumers to take a loan. Consumers actively choose to enter these ecosystems, submit applications, and review the offers presented to them. Both models require consumer consent at multiple stages—from application submission to loan agreement—underscoring that consumer choice is at the heart of these processes.

However, the expansion of ping-post, pay-per-click, and other lead-generation models has drawn scrutiny from federal regulators. The CFPB’s concern is that these tools could be manipulated to steer consumers toward higher-priced products or less favorable options, driven by financial incentives to prioritize specific lenders. This regulatory scrutiny threatens to impose broad controls over digital marketing platforms, potentially stifling innovation and limiting consumer choice.

This regulatory overreach diminishes the effectiveness of tools that help consumers make informed decisions. The real issue isn’t that these platforms steer consumers into “predatory” lending and offer a structured marketplace where consumers can make choices that best fit their needs. By engaging in a marketplace or ping-tree model, consumers can access more credit options than they would if they walked into a single bank or financial institution.

“Third-party ‘lead generators’ continue […] with deceptive tactics.”

Senators Richard J. Durbin, Elizabeth Warren, and others

The “one-to-one” consent rule pushed by the FCC would have altered the regulatory landscape by introducing a new layer of compliance challenges for lead generators and comparison shopping tools. While aimed at bolstering consumer privacy, this rule required explicit, informed consent from users before their data could be shared between platforms or used for targeted marketing. While this sounds reasonable, it would have significantly disrupted the rapid data exchange crucial for efficient lead bidding in ping-post models, introducing delays and additional costs. This would have limited consumer options, particularly from smaller platforms unable to navigate these stringent requirements, potentially pushing them out of the market.

The broader implications are significant. The CFPB’s broad rulemaking and the FCC’s consent rules could create a regulatory chokehold, potentially stripping consumers of the empowerment these tools were designed to provide. Protecting consumer data is essential, but these overlapping regulations risk creating an environment where the tools meant to empower consumers become increasingly inaccessible or obsolete.

“We need to find every way we can under the law to stop [them] from reaching us on our devices.”

—Jessica Rosenworcel, Former FCC Chairwoman

The debate centers around balancing consumer protection and preserving the variety of choices these lead generation models offer. Both marketplace and ping-tree environments fundamentally require consumer involvement and consent at every step. The purest definition of “predatory lending” does not apply to these models, as there is no coercion—only choices. Instead, these platforms provide more access to credit options than traditional banking environments, reinforcing the need to maintain a regulatory balance that promotes transparency without stifling innovation and consumer empowerment.

How America Shops Now

After the financial difficulties that followed Patrick’s divorce, his credit score dropped to around 600. To regain liquidity and rebuild his credit, he applied directly with several credit card issuers: Wells Fargo, Capital One, Self Financial, Chime, Discover, Credit One Bank, and First Progress. Each application followed the defined methodology, tracking every detail from initial inquiry to the final decision.

Unfortunately, the process yielded rejections or incomplete applications across all the institutions, each with its own frustration.

Methodology

This study employed a structured, replicable approach to evaluate the efficacy and user experience of direct credit card applications and those facilitated through comparison shopping tools and lead generators.

Researchers began by entering a standardized set of search queries into Google, such as “best credit cards for bad credit,” “compare credit cards,” and “low interest credit card offers.” Each search string was documented and captured via screenshot to preserve the digital journey. The researchers used incognito browser sessions and cleared cookies between searches to minimize personalization bias in search results.

Researchers followed organic and sponsored links to access application portals from these search results. These portals were categorized by type: either direct (e.g., a bank or credit union’s website) or indirect (e.g., a lead generator, digital intermediary, or comparison shopping tool). Each pathway was logged and visually documented.

For each credit card application, researchers recorded: The total time spent locating the application page and navigating to the submission form; Whether intermediary steps such as account creation or prequalification screenings were required; The clarity and transparency of the application process, rated on a standardized scale; Any friction points that arose, including page errors, vague instructions, or the need for customer support; Security features observed, such as two-factor authentication or CAPTCHA mechanisms.

Approval or rejection outcomes were documented for each submission, and any messaging or feedback was provided to the applicant. Those steps were tracked and described in cases where follow-up verification or additional documentation was required post-submission.

This methodology enabled a detailed comparative analysis across direct and indirect application channels. Emphasis was placed on identifying differences in accessibility, efficiency, and user experience. Combining systematic documentation, visual evidence, and controlled search behavior ensures that this study upholds academic rigor, reproducibility, and empirical transparency.

The Direct Applications

Swipe Left: Wells Fargo

Wells Fargo’s application was straightforward but inevitably futile. After spending 15 minutes filling out the detailed application, including employment history and income verification, our application was rejected. The rejection letter vaguely cited “insufficient credit history” despite the thorough documentation provided.

Swipe Left: Capital One

Capital One’s application involved multiple steps, including a pre-qualification screening that promised a smoother approval process. After a 20-minute application process, Patrick was rejected with a note that said, “Unfortunately, you do not meet our current criteria.” No additional documentation was requested. Patrick already banks with Capital One and has access to a Quicksilver credit card. Capital One did not extend any extra line of credit.

Swipe Left: Self Financial

Self Financial’s credit-builder approach seemed promising. Patrick waited for approval after creating an account. However, they never formally denied the credit card; communication ceased after several emails. The lack of clarity in their process was frustrating and left him without the product he needed.

Swipe Left: Chime

Chime’s application was one of the most convoluted. After setting up a checking account (a prerequisite for their credit-builder card), Patrick was informed he needed to receive a $200 direct deposit within 30 days to unlock credit card eligibility. The card was never offered, leaving him stuck with a checking account he did not need.

Swipe Left: Discover

Discover’s application was quick but ended just as swiftly. Within seconds of hitting submit, Patrick was rejected due to a “credit score below acceptable limits.” The impersonal nature of the process and the need for more detail in their feedback reinforced how challenging it is for consumers in his situation to gain access to credit.

Swipe Left: Credit One Bank

Applying for pre-qualification with Credit One Bank felt like running into a wall. After submitting his information online, Patrick received a rejection letter that cited his inquiry as “suspicious or potentially fraudulent.” This outcome was baffling, as no credit check was performed, and Patrick’s credit score was unaffected. The vague explanation left no room for clarification or recourse, offering little insight into why the legitimate application was flagged. Despite the letter’s suggestion to address potential fraud, the overall experience was marked by confusion and dead ends.

Swipe Left: First Progress

First Progress specializes in secured cards, yet their process was the most tedious. After completing the application and funding the deposit, Patrick was stuck in an endless loop of verification steps. Eventually, his application expired, and he was advised to start over—a discouraging end to an exhausting process.

The Indirect Applications

Swipe Right: Credit Karma and Merrick Bank

While direct credit card applications often involve obstacles and rejections, Patrick’s experience with Credit Karma highlighted the efficiency and accessibility of comparison shopping tools. After being matched with Merrick Bank through Credit Karma, Patrick secured a Double Your Line credit card with a $500 credit limit. This card is designed to help consumers rebuild credit, offering a unique feature to double the credit line after making on-time payments for seven months. The card provides benefits like $0 fraud liability, easy online access and reporting to all three major credit bureaus.

Merrick Bank’s card is tailored for those with subprime credit, providing an accessible pathway for credit improvement. The ability to double the credit line after demonstrating responsible use aligns with the needs of consumers looking to rebuild their financial standing. Moreover, the transparency in the application process, facilitated by Credit Karma’s comparison tool, contrasts sharply with the complex and often frustrating experiences of direct applications.

Their transparency in advertising practices further emphasizes the value of platforms like Credit Karma. Credit Karma discloses that offers are from third-party advertisers who typically compensate the platform, which may influence how offers appear. However, Credit Karma also considers the user’s credit profile, ensuring that recommendations are relevant and beneficial. This transparency undercuts the CFPB’s narrative that comparison shopping tools are inherently deceptive or driven solely by financial incentives.

In this evolving landscape, the seamless experience provided by Credit Karma and Merrick Bank illustrates the importance of maintaining consumer access to innovative financial products. As federal agencies, including the CFPB, increase scrutiny of digital comparison tools, it is crucial to recognize the tangible benefits these platforms offer, especially to consumers traditionally underserved by the financial industry.

While this study’s indirect application focused exclusively on Credit Karma, it is worth noting that other well-established comparison shopping platforms—such as NerdWallet, WalletHub, and LendingTree—operate on similar principles of algorithmic connection and consumer-centered recommendations. Though not explicitly tested here, these platforms serve millions of users and offer comparable tools for discovering credit opportunities tailored to individual financial profiles. The positive outcome achieved through Credit Karma reasonably suggests that similar results could be expected across these peer platforms, further underscoring the value of preserving access to these digital intermediaries in today’s credit marketplace.

Government Matchmaker

The prospect of a government-run lead generation or comparison shopping tool akin to GovLoans.gov would be a disaster for consumers and the broader marketplace. GovLoans.gov, which is undergoing updates, hints at an attempt to enter this space in a more significant role. However, such efforts would need to be revised compared to private sector giants like Google, Credit Karma, and other established platforms.

Imagine the inefficiency: government agencies need help with bloated processes, outdated technology and lackluster user experiences. If they were to develop a comparison tool, they would directly compete with highly sophisticated systems that have refined their algorithms and user interfaces over decades. Government programs do not have the resources or capacity to match the technological prowess of these tech behemoths.

The danger extends beyond financial services. Regulatory overreach by agencies like the CFPB now threatens digital marketplaces across various sectors—from Expedia for travel to Sittercity for finding child care to Angi (are Angi and Angie’s list the same thing?) for home services. The CFPB’s recent moves could set the stage for government-controlled digital matchmaking across these sectors, potentially driving out competition and stifling innovation.

If implemented, a government tool would likely funnel consumers toward limited options dictated by bureaucratic priorities rather than consumer needs. The market-driven comparison tools empower consumers by offering broad, customizable and transparent choices. A government-run system would do the opposite, locking consumers into predetermined choices with little regard for their preferences.

In a world where Expedia or Google could be forced to bow to government-driven “fairness” in how they present choices, consumers would lose the benefits of market-driven competition. The result would be a stagnant digital landscape where efficiency and innovation are sacrificed on the altar of misguided “fairness” and control.

A government-run comparison tool is fundamentally ill-suited for a marketplace that thrives on innovation, speed, and consumer-driven choices. The stakes extend well beyond financial services, threatening the principles of free market competition in economic sectors.

The Ripple Effect

Recent federal regulations from agencies like the CFPB, FTC, and FCC form a coordinated campaign to tighten control over consumer credit and financial services, threatening the existence of comparison shopping tools and lead generators. This push extends beyond the financial sector, as regulatory measures increasingly encroach on communication channels vital to these tools. The CFPB’s new rules target both the financial services pipeline and the platforms facilitating consumer connections.

Before the Eleventh Circuit of the United States Court of Appeals vacated the FCC’s “one-to-one” consent rule in January of this year, it was a textbook example of government overreach. It attempted to introduce complex requirements for individualized consent in communications—a move that could have crippled the lead generation industry. The rule would have had drastic consequences, such as disproportionately burdening smaller firms, driving many out of business, while resulting in less competition and fewer consumer choices. This burden, coupled with Chopra’s aggressive CFPB policies, reflected a broader effort to suppress the industry by creating insurmountable operational barriers during the years of the Biden administration.

The CFPB’s push to eliminate so-called “abusive” or “predatory” practices by comparison shopping tools and lead generators is similarly misguided. While platforms like Credit Karma provide clear disclosures about how compensation from advertisers may influence the order of product offers, the CFPB insists that these practices could exploit consumer trust. Such rhetoric paints a distorted picture of how digital marketplaces function, ignoring that consumers benefit from a more personalized shopping experience that aligns with their needs.

Furthermore, the triple alliance highlights a coordinated strategy to centralize control and restrict financial services arbitrarily deemed ideologically unacceptable. Whether by targeting data-sharing practices or communication consent requirements, these agencies are working together to dismantle alternative financial options under the guise of consumer protection. The natural consequence is reduced access to credit, higher costs, and stifled innovation, especially for consumers with less-than-perfect credit who rely on these tools.

To counter this trend and stop the ripple, policymakers must recognize the value of comparison shopping tools, marketing engines, and the lead generation model in enhancing consumer choice and competition. The future of digital marketplaces should be driven by innovation and free-market principles, not by regulatory overreach designed to control and limit consumer options.

What’s Next?

Comparison shopping tools and lead generator websites are more than just conveniences; they are essential to a modern, consumer-centric marketplace. These platforms, whether a marketplace model like Credit Karma or a ping-tree system used by subprime lenders, enhance competition and democratize choice. By offering transparent, efficient, and accessible options, they empower consumers to navigate the financial landscape more effectively, ensuring they have a broad spectrum of choices to find suitable credit opportunities that align with their needs.

Despite the criticism that these tools promote “predatory lending,” the reality is that both marketplace and ping-tree models operate on consumer choice and consent. No consumer is forced to take a loan; every step involves informed decisions, from application submission to accepting loan terms. Predatory practices, by definition, suggest coercion or exploitation, but in these frameworks, consumers initiate contact, compare options, and agree to terms with full transparency. This challenges the notion of predation and highlights the importance of consumer empowerment in financial transactions.

However, growing federal regulatory oversight poses a risk to this progress. Agencies like the CFPB and FCC are expanding their reach, potentially stifling the innovations that make these platforms valuable. While Chopra and Rosenworcel are no longer in their respective positions at the CFPB and the FCC, their actions could still have long-ranging consequences. While the “one-to-one” consent rule was struck down in court, who is to say that those similar regulations aimed at burdening consumers will not come up again in the future? How will new CFPB Director Jonathan McKernan and new FCC Chair Brendan Carr seek to alter the rules and regulations their predecessors attempted to put before them?

Policymakers must recognize that these platforms provide vital alternatives to traditional banking, especially for those who lack access through conventional means. The focus should be on preserving a dynamic marketplace where consumers have the freedom to choose and the tools to make informed decisions. In a world where consumers can swipe right for better experiences and tailored financial solutions, the market, driven by innovation and choice, should lead the way.

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Products such as Credit Karma and NerdWallet benefit consumers, do not harm them: report https://t.co/SGTM7UT8rH

— FOX Business (@FoxBusiness) May 10, 2025

Notes

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DOI: 10.13140/RG.2.2.35869.01761

This report is also available as a PDF.