Navigating New Trigger Lead Rules: The Total Expert Advantage 

The U.S. House of Representatives recently passed H.R. 2808, also known as the Homebuyers Privacy Protection Act (HPPA), which is designed to curb the abusive practice of “trigger leads.” The House and Senate still need to reconcile the bill before final approval (we fully expect it to pass), but the mortgage industry is already buzzing about how this might limit prospecting and lead generation strategies. 

Total Expert already gives our customers fine-grained controls to comply with this proposed legislation. The HPPA only affirms the relationship-driven strategies already proven by leading lenders—the kind Total Expert was built to enable and enhance. 

Here’s everything you need to know about this proposed legislation: 

What is the “trigger leads” ban? 

Trigger leads occur when a consumer applies for a mortgage, triggering an inquiry to a credit reporting agency (CRA), which then sells that consumer’s contact information to other lenders—often without that consumer’s knowledge or explicit consent. The lenders that purchase these trigger leads then use them for lead generation campaigns. For the consumer, this often means a barrage of unwanted calls, texts, and emails. 

HPPA would to restrict the sale and use of these trigger leads, prohibiting CRAs from selling (or otherwise “furnishing”) consumer reports related to residential mortgage transactions—with a few key exceptions. 

The larger goals are to protect consumer privacy and reduce predatory practices that undermine trust. The more immediate goal is to ensure that consumers applying for a mortgage aren’t immediately subjected to a deluge of unsolicited offers from unknown lenders that mislead borrowers and create significant confusion.  

What is permitted under the proposed law? 

As currently written, HPPA leaves room for trigger leads to be purchased and leveraged by lenders if they fit into one or more of the following categories: 

• The lender has originated the current residential mortgage loan of the consumer to whom the consumer report relates 

• The lender is the servicer of a current residential mortgage loan of the consumer to whom the consumer report relates 

• The lender is an insured depository institution or credit union AND holds a current account for the consumer to whom the consumer report relates.   

• The lender has obtained consent from the consumer and can provide documentation of such consent to a credit agency if needed. 

The common theme here is that these are all situations where the lender has either an existing business relationship with the consumer or has received explicit consent from the consumer to be monitored by the lender. 

What does HPPA mean for Total Expert customers? 

We built the Total Expert platform to help our customers make more genuine human connections and build authentic, lasting relationships. No good relationship ever started with unwanted badgering, so fully respecting consumer consent and privacy was a foundational priority from Day 1 at Total Expert. 

More to the point, we designed the Total Expert platform to balance automation with granular control—to make sure you’re talking to the right people at the right time. Our built-in safeguards already prioritize responsible engagement. These controls ensure you’re only engaging with individuals with whom you have an existing relationship, or those who have explicitly opted into communications from you. This means: 

• You’re focusing on truly high-value opportunities. You can use Total Expert to identify and nurture leads where a foundation of trust or clear interest already exists. 

• You’re deepening existing relationships. You can lean on Total Expert’s Customer Intelligence and journey orchestration to engage your members and customers with relevant, timely offers, rather than endlessly chasing cold leads.  

• You’re building trust, not jeopardizing it. By respecting privacy and giving you insights and tools to engage thoughtfully, we’re helping you reinforce your brand reputation and foster trust that defines long-term loyalty. 

What’s next? 

We’re closely monitoring the status of the HPPA. We will continue to support our customers in navigating and complying with any new requirements that emerge as part of this proposed legislation. We’re committed to giving you the tools and guidance you need. 

But in a broader sense, this legislation doesn’t change the best practices we’ve always preached. And it shouldn’t change the relationship-driven strategies our customers have developed through the Total Expert platform. Instead, this is a clear signal to double down on engaging with precision, relevance, and (above all) genuine respect for your customers and members. That’s how you win customers for life! 

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