So yesterday I reported on the comments from the NCLC and PK. Last week we covered REACH and some (great) industry commentary. Today I want to address a little of the comments from three household names – Tree, Quinn and United Health, and boy do they pack a punch!
rental tree
Lending Tree, probably the best-known brand in comparison shopping, nailed it with the old “when banks compete, they win” line. Good stuff. And that’s true, in theory.
LT has much to lose if PK’s disastrous proposals become a reality. No wonder it made a powerful comment on its own behalf.
In fact, Lending Tree expertly softens some of the key provisions in the NCLC and PK push to tighten industry restrictions. It clearly rejects the idea of sharing consumer information with anyone on a big list — and acknowledges that doing so puts consumers in touch with only a handful of lenders. And it points to the huge savings consumers enjoy when they use comparison sites like LT.
Tree also explains why enforcing all names in a consent disclosure is cumbersome for consumers, inconsistent with current website operations, and negatively impacts the user experience. Good stuff.
LT suggests that the better way – which I’ve heard from many in the industry – is to allow the publisher to notify the consumer of the match after a match has been made. This is somewhat similar to the hotwire.com model, where you only learn the name of the hotel after you have paid for it. As Tree explains, this model allows the website operator maximum flexibility – to the consumer’s benefit – but also limits the number of possible matches and ensures consumers know who they have been matched with.
Finally, LT is asking the FCC to reject PK’s more “extreme” restrictions. According to LT, the PK model destroys competition and deprives consumers of choice.
Quinn Street
It’s not a beauty pageant, but if I had to vote for the best comment, the ranking would be REACH, Drips, QuinnStreet.
This thing has it all. A very comprehensive overview of how the industry works – which is crucial for the Commission – a brilliant defense of the price comparison model and a thorough command of practical and legal principles.
Not surprisingly, Quinn supports the “logically and thematically” related standard – just like REACH – and focuses his fire on urging the Commission to reject the hyperlink proposal and the PC proposal.
Regarding PK, QuinnStreet presents the problem that the FCC has previously rejected PK when drafting the CFRs – which is pretty clever – and urges the Commission to simply ignore the cantankerous consumer lobbyists and not understand how things are done really work.
This one is worth reading. Very, very strong. QuinnStreet comment
United Healthcare
Last but not least, United Healthcare should be mentioned.
Another extremely strong comment: UH urges the Commission to understand that shutting down lead generators is causing enormous harm to consumers. And, especially in healthcare, it can be very difficult for consumers to navigate the different options. Connecting consumers with licensed representatives 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, that works. Very powerful stuff.
As UH explains, lead generators don’t sell insurance, they are important “connecting channels” that connect people with those who can provide much-needed answers. This leads to five highlighted benefits: 1. Education; 2. More options; 3. Good prices; 4. convenience; and 5. fewer scams.
The last point is particularly important as it contradicts the narrative that lead generators are the scammers. Not true! Qualified information channels help consumers AVOID being taken advantage of – and I love that UH is speaking up and making that clear.
Really great thing. You can read her comment here: United Healthcare.05082023
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tcpaworld.com
https://tcpaworld.com/2023/05/16/the-big-boys-heres-what-lending-tree-quinnstreet-and-united-healthcare-had-to-say-on-the-fccs-nprm/
