As John Sandman wrote in his award-winning series (which was funded by the Investigative Fund at the Nation Institute):
According to the Consumer Federation of America, only 18 states ban or strictly regulate payday loans. New York's ban is one of the nation's toughest. … [But] Internet payday loan companies never stopped lending to New Yorkers. … Some online lenders take pains to avoid states that have bans or restrictions. Some will deny you a loan because you live in a state with a ban, like New York — then send you to a lead generator that will identify a lender for you.
Indeed, lead generators figure prominently in the new enforcement push, according to the Times:
New York State’s financial regulator, Benjamin M. Lawsky, sent subpoenas last week to 16 so-called lead generator websites, which sell reams of sensitive consumer data to payday lenders, according to a copy of the confidential document reviewed by The New York Times. The subpoenas seek information about the websites’ practices and their links to the lenders.
In a statement on its website, DFS says, "Through promises of access to quick cash, the lead generation companies entice consumers to provide them with sensitive personal information – such as social security and bank account numbers – and then may sell that information to payday lenders operating unlawfully in New York and other companies.
"As part of its investigation, DFS has heard complaints from New York consumers against a number of these lead generation firms about false and misleading advertising (including celebrity endorsements), harassing phone calls, suspicious solicitations, privacy breaches, and other issues."