Trigger lead

A trigger lead is a prospect list a credit bureau assembles from the fact that a lender has just pulled somebody's credit for a mortgage. The inquiry is the trigger. The bureau sells the name onward, and the buyer calls a borrower who is known to be mid-application somewhere else. The phrase is industry vocabulary rather than a term any statute uses.

How a mortgage inquiry becomes a list for sale

A lender pulls a borrower's credit to price a loan, and the bureau records the inquiry. The prescreening provision of the Fair Credit Reporting Act, at 15 U.S.C. 1681b(c), lets a bureau furnish a report for a transaction the consumer never initiated, so long as the transaction is a firm offer of credit or insurance and the consumer has not elected to be excluded from such lists under 1681b(e). That permission is what made the list saleable.

Why the calls arrive within hours

Speed is the product being sold. A list built off a fresh mortgage inquiry names people who are shopping this week, so buyers of that list dial within hours, sometimes inside the first one, while the borrower is still reading the paperwork from the lender they picked. The borrower asked nobody for those calls and frequently cannot tell which caller is the lender holding the application.

The legal status since 4 March 2026

The Homebuyers Privacy Protection Act, Public Law 119-36, added a paragraph to section 604(c) of the Fair Credit Reporting Act. Section 3 set the effective date at 180 days after enactment, and enactment was 5 September 2025, which counts out to 4 March 2026. From that date a bureau may not furnish a report off a residential mortgage inquiry to a party with no relationship to the borrower.

The remaining permitted recipients are a short list. The transaction has to be a firm offer of credit or insurance, and the recipient has to have filed documentation with the bureau certifying the consumer's authorization, or have originated the consumer's current residential mortgage loan, or service that loan, or be an insured depository institution or credit union holding a current account for that consumer. The full reading, including why a large share of trade coverage prints 5 March 2026 rather than the 4th, is in what the trigger lead ban stopped.

One number a buyer will be quoted about trigger leads is not printed here. A share-of-pipeline figure circulates widely in vendor and lender material; it was looked for and no study or filing stands behind it, so no version of it appears on this page.

The measurement that would settle it is late. Section 4 of the same Act directed the Comptroller General to study trigger leads received by text message and report to Congress "not later than the end of the 12-month period beginning on the date of enactment". That is the construction the effective date uses, read the same way: a 12-month period beginning 5 September 2025 ended on 4 September 2026. The deadline has passed and no such report appears on the public record. A late report to Congress is ordinary and carries no penalty, but until it lands, every figure in circulation comes from a firm that sells leads, one that buys them, or a body speaking for one of the two.

Source: Fair Credit Reporting Act, prescreening provision at 15 U.S.C. 1681b(c) and the consumer's election to be excluded at 15 U.S.C. 1681b(e) · "Firm offer of credit or insurance" is defined at 15 U.S.C. 1681a(l) · Homebuyers Privacy Protection Act, Public Law 119-36, section 2 (the new paragraph in section 604(c)), section 3 (effective date, 180 days after enactment) and section 4 (Comptroller General study), enrolled text at govinfo.gov · Enactment date 5 September 2025, from the enrolled text's closing "Approved September 5, 2025", which counts out to 4 March 2026.