HR 2808: Credit Trigger Leads Are Changing

Credit Trigger Leads are Going Away. Is Your Marketing Strategy Ready?

HR 2808—The Homebuyers Privacy Protection Act—has cleared Congress. Once signed into law, it will ban the resale of credit trigger leads to unaffiliated lenders.

This will rewrite how lenders, vendors, and lead buyers engage with mortgage shoppers. What you do next matters.

This is a big deal if  your acquisition model depends on these kinds of leads. If so, it’s time to rethink your strategy. Our Strategic POV on HR 2808 breaks down what’s changing, what’s not, and how forward-thinking marketers can move ahead with confidence. Here’s a preview of what’s inside:

What’s Changing for Credit Trigger Leads?

Trigger leads are created when a borrower applies for a mortgage. Credit bureaus detect the credit inquiry and turn that signal into a lead that’s sold to multiple competing lenders, often without the borrower’s knowledge.

This practice will soon be off-limits. HR 2808 bans the sale of mortgage credit trigger leads to unaffiliated lenders, closing the door on a major acquisition channel for many in the lead generation and acquisition space.

What’s Here to Stay?

While the bill targets credit trigger leads, not all lead generation is affected. The law does not ban:

• Opt-in lead generation via TCPA-compliant web forms, quote requests, or pre-qualification tools
• Leads driven by digital advertising and rate comparison platforms
• Partner or affiliate programs with consumer consent
• Data models based on behavioral intent signals (such as browsing behavior and activity)

That means smart marketers still have options, they just need to pivot toward permission-based and behavior-informed strategies.

Is Your Lead Acquisition Practice Ready?

If you’ve been leaning heavily on credit generated trigger leads, this is a critical moment. You’ll need to examine:

• Where your leads are coming from
• Whether your current vendors and partners are compliant
• How quickly you can shift to consent-based acquisition
• What kinds of data signals you’re using to identify buyer intent

The silver lining? This opens the door to more strategic, sustainable, and compliant lead generation strategies, especially for lenders and vendors who already have strong behavioral data practices in place.

Bet on Behavior-Based Intent Data

Make no mistake,  Now is the time to invest in behavioral intent data and identity resolution.

Credit pulls aren’t the only way to detect home-buying activity. In many ways, they are outdated and deliver a signal that is late in the buyer’s journey—and broadcast intent to all your competitors as well.

Data-informed lenders and marketers can act earlier in the customer journey by tracking signals like:

• Visits to mortgage rate pages
• Engagement with loan calculators or pre-qualification tools
• Quote requests or rate shopping activity
• Interactions with lender and aggregator websites

These behavioral signals, especially when tied to validated identity, allow you to build privacy-compliant, high-intent lead audiences that don’t rely on credit bureau triggers.

How to Stay Ahead of the Curve

In the full POV, we outline four smart steps your team can take now:

1. Audit your current lead sources
   Identify where trigger leads are coming from and which vendors might be affected by HR 2808.
2. Build consent early
   Encourage early engagement through branded tools, educational experiences, and pre-qualification funnels.
3. Enhance your behavioral modeling
   Work with Verisk Marketing Solutions to activate non-credit-based intent signals and improve your targeting and propensity models.
4. Tighten compliance alignment
   Make sure your marketing, sales, and legal teams are ready. New legislation can ripple across operations quickly.

HR 2808 could signal a tectonic shift in how mortgage marketing works. The best-positioned lenders, vendors, and marketers won’t just adapt—they’ll lead. They’ll build smarter, scalable acquisition strategies. Improve targeting. Reduce friction for buyers. And move confidently into a more transparent and permission-based ecosystem.