Trigger leads: What are they, How do they work, Opt-out, Costs

Trigger leads are leads that are generated by three major credit bureaus for lenders and creditors. These leads are based on the recent credit activities of consumers who agreed to have their credit reports pulled. The consumers on the list meet certain criteria that are pre-set by lenders and creditors.

Lenders and creditors purchase inquiry data made by the three major credit bureaus. The three major credit bureaus, Equifax, Experian, and TransUnion, create lists of consumers who recently had a hard inquiry on their credit report. This list of consumers who meet the criteria of lenders and creditors can be sold by the three major credit bureaus through the Fair Credit Reporting Act (FCRA).

The FCRA states that a credit bureau or consumer reporting agency can furnish a consumer report in connection with any credit or insurance transaction that is not initiated by the consumer only if the consumer agrees and if the transaction consists of a firm offer of credit or insurance. This clause under the FCRA allows lenders to purchase trigger leads and use them for marketing and promotional purposes.

The purchase of trigger leads is currently being opposed by House Bill 7661. House Bill 7661 (H.R. Bill 7661) seeks to change the FCRA’s creation and sale of trigger leads in mortgage loans. If signed into law, it will be known as the Trigger Leads Abatement Act of 2022.

Trigger leads: What are they, How do they work, Opt-out, Costs

What Are Trigger Leads?

A trigger lead is a lead that credit bureaus generate for lenders and creditors. These leads are based on the recent credit activities of consumers who agreed to have their credit reports pulled. The consumers on the list meet certain criteria that lenders and creditors pre-set.

Lenders and creditors purchase inquiry data that the three major credit bureaus make. The three major credit bureaus, Equifax, Experian, and TransUnion, create lists of consumers who recently had a hard credit inquiry on their credit report. This list of consumers who meet the criteria can be sold to lenders and creditors by the three major credit bureaus through the Fair Credit Reporting Act (FCRA).

The FCRA states that a credit bureau or consumer reporting agency can furnish a consumer report in connection with any credit or insurance transaction that the consumer does not initiate only if the consumer agrees and if the transaction consists of a firm offer of credit or insurance. This clause under the FCRA allows lenders to purchase trigger leads and use them for marketing and promotional purposes. The consumer credit reporting industry operates under these federal regulations to protect privacy while enabling competitive offers.

The purchase of trigger leads is currently being opposed by House Bill 7661. House Bill 7661 (H.R. Bill 7661) seeks to change the FCRA's creation and sale of trigger leads in mortgage loans through new legislation. If signed into law, it will be known as the Trigger Leads Abatement Act of 2022. The American Bankers Association (ABA) and other bankers have weighed in on this proposed legislation.

Do Trigger Leads Work?

Yes, trigger leads work for lenders and creditors in the mortgage industry. Lenders and creditors are notified when a consumer's credit report is pulled. A trigger lead contains the consumers' names, addresses, contact information, and financial information, such as FICO® Scores and credit balances. This information is used to prescreen potential customers for different lender products, including home loan options.

Lenders can ask the major credit bureaus or consumer reporting agencies for a list of people within their database who meet the lender's pre-set criteria. Aside from that, the lender can also submit a list of potential customers to the major credit bureaus or consumer reporting agencies and request to identify which contacts from the list meet the established criteria. Banks and other finance institutions use these trigger leads to reach customers who have applied for credit.

Can You Opt-Out Of Trigger Leads?

Yes, you can opt out of trigger leads if you are not in the market for financing or insurance. The FCRA states that you may elect to have your name and address excluded from any list that a consumer reporting agency or major credit bureau provides. This list is in connection to a credit or insurance transaction that you do not initiate. You can notify the consumer reporting agency or credit bureau that you do not agree to the use of your consumer report in connection to any credit or insurance transaction that you do not initiate.

You can notify a consumer reporting agency or credit bureau through the notification system that the agency maintains or by submitting a signed notice of out election form that the agency issues. Consumers have the right to protect their privacy by opting out permanently or for a specified period. Keep in mind that you may have to complete this request in writing according to the agency's requirements.

How Much Do Mortgage Trigger Leads Cost?

Mortgage trigger leads cost around $20 - $150, depending on the conversion rate. A conversion rate of 2-4% trigger leads ranges from $20 - $50, which may require a lot of effort on selling and follow-up. Trigger leads with a 5–10% conversion rate cost around $100 - $150. Bank and finance companies evaluate these costs to determine if they can get a better return on investment.

Are Trigger Leads Compliant?

Yes, trigger leads are compliant under the FCRA as long as the company that is buying the trigger leads meets certain legal requirements that the FCRA states. The Federal Trade Commission (FTC), which implements the FCRA, supports trigger leads because it gives consumers competitive prices in order to get the best deal possible for mortgage loans. Consumer finance protections remain in place even as the credit reporting industry can sell these leads to lenders.

Can Consumers Prevent Trigger Leads?

Yes, consumers can prevent trigger leads in the future by opting out, as the FCRA states. The FCRA is a federal law that regulates the collection of consumers' credit information and access to their credit reports. The enforcement of the FCRA relies on the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB). The FTC is a U.S. agency that protects consumers from unfair and dishonest business practices and unfair competition by using law enforcement, advocacy, research, and education. The CFPB is a U.S. agency that ensures that banks, lenders, and other financial institutions treat consumers fairly. These protections can help reduce the risk of scams and fraud from scammers who use trigger leads for telemarketing and spam.

Who Uses Trigger Leads?

Many types of companies use trigger leads. Companies such as mortgage lenders, auto lenders, car dealerships, credit card providers, insurance companies, and personal loan providers buy trigger leads. These companies use consumer information from trigger leads to market their products and acquire more customers. A third party can also purchase these leads to offer home loan products or other consumer credit services.

How To Stop Trigger Leads

There are several steps to stop the trigger leads. The first way is to register at optoutprescreen.com or call 1-888-5-OPTOUT (1-888-567-8688). The three major credit bureaus operate the opt-out website and phone number. This gives you options to opt out for five years or opt out permanently. You will need to provide the following personal information, such as your name, address, Social Security Number (SSN), and date of birth, to request to opt out. The FCRA mandates that requests to opt out are processed within five business days. It will take a couple of weeks to complete and take effect in terms of getting prescreened offers. Keep in mind that this won't stop all junk mail from other sources.

The second way to stop the trigger leads is to sign up at the National Do Not Call Registry (donotcall.gov) or call 1-888-382-1222. You will need to register the phone number at the registry that you want to be opted out from trigger leads. The sales calls from trigger leads can take up to 31 days to stop. You may still receive calls for political reasons, charities asking for donations, survey requests, collection calls, or information calls. The information calls are used by some lenders or creditors to provide information about their products. You can report violations to the official consumer protection agencies if telemarketers continue to call.

The last way to stop the trigger leads is to sign up at Direct Marketing Association or DMAchoice.org. DMAchoice.org, by the Association of National Advertisers (ANA), prevents mail offers or prospect mail from companies with whom you don't have a business relationship from being sent to your physical mailbox, reducing junk mail. The registration fee is $4 for online and $5 for mail-in registration, which is good for ten years. ANA states that DMAchoice may reduce the overall volume of promotional offers by 80%, but it cannot eliminate all promotional mail, especially from companies or organizations you've had business with within the past two years. Signing up for this service can help you manage unwanted emails and physical mail.

Mortgage Trigger Leads

Mortgage trigger leads are obtained by mortgage professionals using lists from credit reporting agencies or one of the major credit bureaus. This list contains the consumers' names, addresses, and contact information based on their recent credit activities, such as when they apply for a mortgage. Credit activities such as mortgage applications are considered hard inquiries, which require the credit reporting agencies or major credit bureaus to pull the consumers' credit reports.

Consumers' information is included in the mortgage trigger leads whenever they sign a loan application, which gives permission to credit reporting agencies or national credit bureaus to pull their credit reports. This process creates a trigger that notifies mortgage lenders or mortgage companies that consumers are starting to shop for mortgages. The consumer will never know immediately when their information has been sold to other lenders. You're here reading this because you want to understand how trigger leads work and how they may affect your privacy when you apply for a home loan. The credit reporting industry will continue to operate under current rules unless new legislation passes to place additional restrictions on the practice.