HR 2808 Is Now Law, Here’s What Financial Services Marketers Need to Do Next

In our last post, “HR 2808: Credit Trigger Leads Are Changing,” we unpacked what this legislation means for the industry.Now that the Homebuyers Privacy Protection Act (HR 2808) is officially law, let’s talk about what happens next:

Starting March 4, 2026, credit bureaus will no longer be allowed to sell mortgage trigger leads to unaffiliated lenders, unless specific conditions are met. This change marks a major disruption for financial services marketers who have long depended on bureaus to build their lead acquisition strategies.

The Black Box That Broke Acquisition

Trigger-based programs once promised speed. A borrower applied, a bureau logged the inquiry, and that signal was resold to dozens of lenders, all racing for the same consumer. But that model had cracks that widened over time:

• Late to the game: Triggers fire after borrowers have already spent weeks researching and comparing lenders
• Blind targeting: You don’t know who’s in the file until the results come in
• Shared data, shared pain: Every competitor gets the same names at the same time
• Fuzzy attribution: It’s hard to know which marketing tactics worked, and where
• Compliance risk: High-volume, low-context data that you no longer control

It became known as a prospecting “black box,” filled with delayed signals, zero transparency, and rising costs per funded loan. That uncertainty might have been acceptable when leads were cheap, but those days are over.

From Reactive to Proactive, and Predictive

Marketers who succeed in this new era won’t wait for triggers, they’ll anticipate intent before it happens.

Verisk Marketing Solutions built Activate and Total Consumer Insights (TCI) In-Market Scores, two connected solutions that replace lagging bureau triggers with verified behavioral signals.

• Activate monitors your existing customer and prospect databases close to the moment of shopping activity. It surfaces identity-resolved behavioral signals across more than 25 categories including mortgages, personal loans, and credit cards, revealing when consumers are actively researching or cross-shopping elsewhere.
• TCI In-Market Scores build on those same observed signals. They model which consumers are most likely to be in market, turning real behavioral data into predictive reach that scales beyond your known audience. The result: compliant, high-performing audience intelligence you can activate in any channel, from paid and email to direct mail or CRM.

Backed by a proprietary network of 55,000 shopping sites and powered by 2 billion observed consumer intent signals each quarter, Activate and TCI In-Market Scores work together to turn guesswork into precision.

You stop reacting to credit pulls and start acting on verified behavior, sooner, smarter, and with total transparency.

Compliance Is the Catalyst, Not the Limit: Get Ready for What’s Next

HR 2808 doesn’t close doors, it opens them. By replacing opaque, third-party data with transparent, consumer-driven signals, marketers can stay compliant, act earlier, and gain measurable performance advantages.

Our new guide, Prospecting After HR 2808: A Guide for Financial Services Marketers, dives deeper into how to build acquisition programs that thrive in this new regulatory environment, how to re-engineer campaign timing, audience modeling, and measurement for the post-trigger world.