So yesterday I covered the NCLC and PK’s comments. Last week we covered R.E.A.C.H. and a few (great) industry comments. Today I want to zoom in a bit on the comments of three well known names– Tree, Quin and United Health, and boy do they pack a punch!
Probably the best known brand in the comparison shopping space, Lending Tree made it big with the old “when banks compete you win line.” Good stuff. And true, in theory.
LT has a lot to lose if PK’s disastrous suggestions come to fruition. No surprise it submitted a powerful comment in its own name.
Indeed, Lending Tree expertly disarms some of the key provisions in NCLC and PK’s push to tighten industry restrictions. It clearly denounces the idea of sharing consumer information with everyone on a large list–confirming that it only connects consumers with a handful of lenders. And it points out the vast savings enjoyed by consumers who use comparison shopping sites like LT.
Tree also explains why forcing all names to appear on a consent disclosure is cumbersome for consumers and inconsistent with current website flows and bad for user experience. Good stuff.
LT suggests the superior path–which I have heard from many in the industry–is to allow the website operator to inform the consumer of the match after one has been made. This is sort of like the hotwire.com model where you only learn the name of the hotel after you’ve paid for it. As Tree explains, this model allows maximum flexibility for the website operator–to the consumer’s benefit–but also limits the number of matches that can take place and assures consumers know who they were matched with.
Finally, LT urges the FCC to reject PK’s “more extreme” limitations. In LT’s view the PK model destroys competition and deprives consumes of choice.
Its not a beauty pageant, but if I had to vote on best looking comment the rankings would go R.E.A.C.H, Drips, QuinStreet.
This ting has it all. A very comprehensive review of how the industry works–really critical for the Commission to be armed with– a brilliant defense of the comparison shopping model, and an overall mastery of practical and legal principles.
Unsurprisingly, Quin comes out IN SUPPORT of the “logically and topically” related standard–just as R.E.A.C.H. did, and focuses its fire on urging the Commission to reject the hyperlink proposal and the PK proposal.
On PK, QuinStreet frames the issue as the FCC having already rejected PK previously in drafting the CFRs–which is pretty clever–and urges the Commission to simply ignore the quarrelsome consumer lobbyists and not understanding how things really work.
This one is worth a read. Very very strong. QuinStreet Comment
Last, but not least, is United Healthcare.
Another extremely strong comment, UH urges the Commission to understand that shutting down lead generators harms consumers tremendously. And in healthcare in particular navigating options can be very tough for consumers, connecting consumers with licensed agents who can help them understand coverage issues is absolutely CRITICAL and anything the Commission does to limit patient access to provider options is potentially very damaging.
Wow does that resonate. Very powerful stuff.
As UH explains matters, lead generators are not selling insurance but they are critical “conduits” connecting folks to those who can provide much needed answers. This leads to five highlighted benefits: 1. Education; 2. More options; 3. Good pricing; 4. Convenience; and 5. less scams.
That last piece is particularly important as it runs counter to the narrative that lead generators are the scammers. Not true! Qualified channels of information help consumers to AVOID being taken advantage of–and I love UH coming forward and spelling that out.
Really great stuff. You can read their comment here:United Healthcare.05082023