A trigger lead is generated when a consumer's credit is pulled for a mortgage application. The credit bureaus legally sell these inquiries as marketing data to competing lenders within hours of the pull. A borrower who just applied with an MLO may start receiving calls from competitors the same day.
How Trigger Leads Work
When a lender pulls a tri-merge credit report, the bureaus note the inquiry and can package that consumer's contact information as a trigger lead. Competing lenders using trigger lead services may call the borrower within 24 hours of application. Borrowers are often confused or angered by the calls, especially when they believe they have already been approved by their chosen MLO.
The Legal Framework
- ✦Trigger lead marketing is permitted under the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act.
- ✦The consumer can opt out of prescreened offers via optoutprescreen.com, though this takes time to take effect.
- ✦Competing lenders must comply with the TCPA for calls and CAN-SPAM for emails.
How MLOs Can Respond
- ✦Set expectations with borrowers at application: explain that competing calls may occur and why.
- ✦Encourage borrowers to opt out at optoutprescreen.com before or immediately after application.
- ✦Move the borrower quickly toward lock and clear-to-close; once the application is fully processed, the trigger lead has less competitive value.
- ✦Some MLOs purchase their own trigger leads to identify borrowers in their market who are actively shopping.
Aria can help MLOs explain trigger leads to borrowers, identify opt-out options, and structure conversations that reinforce loyalty during the rate shopping window. Ask at vicariointel.com.
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