Mortgage Trigger Lead Restrictions Take Effect March 2026

Effective March 2026, the Homebuyers Privacy Protection Act of 2025 restricts credit reporting agencies from providing residential mortgage trigger leads to any lender or broker that does not already have a relationship with the homebuyer or the homebuyer's consent. The restriction applies to all credit bureaus that sell contact and credit information after a mortgage application is made.

Before the Act, credit bureaus could sell a homebuyer's contact and credit data to multiple lenders and brokers without the borrower's consent, creating a market for "trigger leads." Those leads enabled lenders to contact applicants with competing loan offers, often via phone calls or text messages.

GAO's review notes that industry stakeholders argue trigger leads can encourage comparison shopping, yet a recent federal survey found that no more than 3.5 percent of homebuyers obtained a loan through offers generated by trigger leads. Consumer advocates and lenders alike cite high volumes of unsolicited communications, potential for misleading practices, and privacy concerns as significant drawbacks.

Because the restrictions have been in place for less than a year, GAO reports that there is insufficient data to assess their impact on solicitation volume or on homebuyers' ability to compare loan options. The agency cautions that, if effectively implemented, the limits could reduce unwanted marketing while preserving legitimate comparison-shopping tools such as online rate-shopping platforms and referrals.

GAO based its analysis on a review of federal and state statutes, literature, the 2022-2024 National Survey of Mortgage Originations, CFPB consumer-complaint data, and interviews with credit bureaus, consumer groups, lenders, industry associations, a state banking regulator, and the Federal Trade Commission. For further information, contact William W. Colvin at colvinw@gao.gov.