Customer Engagement

Avoiding Pitfalls When Advertising on Third-Party Websites and Buying Leads

5 mins read
October 19, 2017
By
Total Expert

Advertising on third-party websites and buying leads are both common practices for top producers, but it seems the lines of right and wrong have started to blur. As Mitch Kider, Managing Partner at Weiner, Brodsky, Kider PC says, don’t get lazy about it – do it right and stay compliant.  

The Skinny on Third-Party Website Advertising

Third-party websites and portals are trying to meet the industry’s evolving needs, including: buying and selling leads, marketing, co-marketing, single- and multi-property websites, and CRM systems. The biggest challenge with these types of sites is use of the site in combination with another settlement service provider, especially one who is a referral source. Kider says there is nothing wrong with co-marketing, as long as you do it right.  

So, how can loan officers (LOs) co-market on third-party websites and portals?  

  • The challenge with third-party websites is if they aren’t open to everyone, someone is acting as a gatekeeper. For example, on certain such websites, the only way a Realtor can gain access to the particular site is via invitation from an LO. In this scenario, the LO has given the Realtor something of value and if this is pursuant to an agreement that the Realtor will refer business back to the LO, you now have a RESPA Section 8 violation. In these types of situations, the LO is likely going to invite Realtors who have partnered with them or done something for them. Kider believes these third-party sites should open their doors and allow access to anyone to eliminate the risk of these types of violations. Until that happens, lenders should approach these types of websites and relationships with caution.
  • The Consumer Financial Protection Bureau (CFPB) is concerned with advertising that the consumer will potentially view as a referral. For example, if a lender advertises on a Realtor website, the advertisement must clearly be marked as an advertisement. Paid advertisements can’t say “preferred lender” or anything similar. If an advertisement were to say “Use my preferred lender,” now the lender is paying for the endorsement, not just the advertisement.
  • The best way to determine fair market value for advertising is a combination of impressions and pro-rata share. Ask yourself: How many people are going to see this ad? In addition, if you’re co-marketing, the Realtor and LO should pay for their pro-rata share of the advertisement and cannot defray the other party’s costs. Both parties should pay their reasonable fair market share of the ad based on impressions, size of the ad and their pro-rata share of the total ad costs, among other potential factors.

Lead Buying vs. Referrals

It is important to first define lead buying: When you purchase a lead, it is not a referral, you are buying basic information about a lead who may be interested in purchasing a product you are selling. Purchasing leads is fine.  

However, and this is where the line is getting blurred a bit – you cannot pay for a lead if the party that is selling you the lead also tells the lead that you are a great lender and they should use your services. Then youare not purchasing a lead, you are purchasing a referral.  

To avoid this blurred line, lenders and LOs should not mix lead-sale agreements with marketing, desk rentals or anything else along these lines. Keep the line clear and easy to explain to a regulator.  

Purchasing leads has been very effective and will continue to be very effective, but do not get lazy about it – if you buy a lead, it is the LO’s job to go out and win the business themselves, not to pay someone to recommend them.

The Lesson: Do Not Get Lazy

Advertising on third-party websites and lead buying are perfectly fine in the mortgage industry. The key is to not get lazy about it – do it right and do not let the lines get blurred.

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Reflections on Accelerate 2025: Aiming at a New Necessary

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What a week. I walked into this industry ten months ago with fresh eyes, full of respect for the impact this industry has on people’s lives. After spending time with our clients and partners at Accelerate—during sessions, hallway conversations, and yes, even at the parties—that respect has deepened. This isn’t just an industry. This is a community of passionate, talented people who don’t simply originate loans or manage portfolios, they create life-changing opportunities for millions. You care deeply about doing this work, and I’m grateful to be building alongside you.

But here’s the thing: we’re at a turning point. What got us here, the strategies that helped us retain and grow in the past, are no longer good enough. You might say it is necessary, but not sufficient, and the cost of waiting is higher than the cost of change. The forces reshaping our industry aren’t on the horizon; they’re sitting at the table. AI technologies, increasingly complex compliance, mergers and acquisitions, shifting consumer demands. It’s not a question of whether we’ll adapt, it’s whether we’re adapting fast enough.  

That’s why, at Accelerate, Joe and I introduced the concept of the “new necessary” as part of our Aim Higher conference theme. Staying relevant (and competitive) requires more than awareness, automation, or clever content. It requires deep, enterprise-ready context that powers systems of intelligence and action. Systems where originators and AI work together in sync—always on, highly consistent, endlessly scalable. Your feedback, and the results we’ve seen so far, tell me we’re on the right track. And. Have a lot to do!

Throughout the conference, I spoke about four pillars of focus: Strengthening the Foundation, Customer IQ, Lead Management, and AI. Here’s a quick tour.

Strengthening the Foundation

This year, we doubled down on the foundation of Total Expert: improving core capabilities, enhancing performance, expanding our ecosystem, evolving user experience. At Accelerate, we demonstrated real progress: faster email delivery, more tools to utilize SMS, automated marketing packages, Sales Manager Dashboards, and new integrations. That’s great progress. More is necessary. We are on it!    

Customer IQ

Agentic AI enables business value when it’s fueled by rich, accurate, and timely context.  The insights and enrichment from Customer Intelligence is necessary and drives great business outcomes. However, more is needed to take full advantage of what’s possible with AI Agents acting as high-performing members of your team rather than wasting time and money on bland generic agents operating with limited context.

That’s why we announced Customer IQ. We are deepening our commitment to dramatically increase context across four dimensions; enrichment and insights, consent, contact/customer information, and relationship history.  As an early example, in December we’ll be releasing new capabilities to enable the collection and aggregation of consent from multiple systems directly into Total Expert. That means our AI Sales Assistant can instantly understand consent and act on it- accurately and efficiently. More context expansions are already queued up for 2026.

Lead Management: Reimagined

We’re launching the first release of our revamped Lead Management in February. This isn’t just a tune-up; it’s a rebuild. From lead ingestion and routing policies to loan officer workflows, admin tools, journey orchestration, and analytics—this release sets the stage for what’s coming next. And it’s just the beginning. Stay tuned for more updates soon.

Agentic AI and AI Services

At Accelerate, we showcased real results from the AI Sales Assistant. Four use cases are live today, and we’re handling millions of calls each month. This volume has accelerated performance most importantly, customer results. With the right combination of context, industry expertise, and integrations into business processes, we’ve unlocked a recipe for success. We’re continuing to expand on this, with exciting new use cases on the horizon.

We also shared our vision on Agentic Management, or the “control tower,” and our early work on AI services like Natural Language Interfaces. These are key to driving more intelligence, more automation, and better user experiences across the platform. A good example of this is the demo of the natural-language data interface, which was a personal highlight for me as a preview of the seamless, intuitive future we’re working toward.

Why this Matters

Our mission is simple: help you retain and grow. How? By enabling you to execute the perfect customer journey, fueled by context, driven consistently by orchestrated journeys, executed by both humans and intelligent agents working in harmony, with a virtuous feedback loop. Always on and enterprise-grade.    

This is the new necessary.  

I’m incredibly fired up about our vision, our momentum, our roadmap, and the amazing work we get to do alongside our clients, partners, and teammates. At the end of the day, it’s not about the technology. It’s about the business value it enables. The customers who are leaning into what we’re building are becoming more competitive. Those that aren’t risk falling behind.

I hope that Accelerate, this post, and our community give you the inspiration and insights you need to chart your next steps toward the new necessary—the why, the how, and the when.  

Thank you, as always, for your feedback, your drive, and your partnership. Let’s keep moving toward the perfect customer journey!

Pete

Mortgage

Smaller Lenders, Bigger Impact: Using Data to Deepen Personal Relationships

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Forming authentic relationships has always been the competitive edge for smaller lenders. And as the FinServ world has become more tech-driven and digital-first, credit unions and community banks have only leaned further into this powerful differentiator. But we’re seeing an interesting trend among some of the most successful small- to mid-market lenders: They’re recognizing that tech-enabled engagement is no longer mutually exclusive to genuine human connections. They’ve created powerful data-driven strategies that make it easier for them to build good, old-fashioned personal relationships.

These forward-thinking lenders are realizing that their smaller size is actually an advantage in implementing “big data” tools and strategies. We’re seeing credit unions and community banks deploy Total Expert Customer Intelligence in a matter of weeks and start realizing value in as little as 90 days, building a loyalty- and revenue-generating engine that fuels itself.

But how are they doing it in a financial landscape where consumers have more choices and competitors aren’t just in the building across the street?

Even close borrower relationships are growing more complex

Small- to mid-market lenders have been historically hesitant to embrace tech-powered, data-driven strategies because there was a concern that it would dehumanize their connections with borrowers. Which is understandable as community banks and credit unions have built their brands and their reputations on their ability to forge honest, transparent relationships—getting to know their customers and members in ways bigger lenders could only dream of.

But even those 1:1 borrower connections are now digital-first, multi-channel relationships. Those increasingly complex relationships involve exponentially more data, information, preferences, and intent signals. A common concern we hear among smaller lenders runs along the lines of, “We don’t have enough data for a ‘Big Data’ strategy.” But the truth is that even the smallest credit unions and community banks are swimming (and sometimes drowning) in a pool of tremendously valuable data.

Borrowers expect to feel “known” across every channel; they want the same feeling of 1:1 personalization at every touchpoint. And it’s becoming a genuine challenge for smaller lenders to juggle all the information and orchestrate these hyper-personalized omnichannel experiences.

Using Customer Intelligence + marketing automation to enhance personal borrower relationships

More and more credit unions and community banks are turning to data-driven, tech-enabled strategies to complement—not replace—their personal relationships with borrowers. We’ve seen smaller lenders have tremendous success with Customer Intelligence and our dynamic, automated Journeys because they:

  • Surface intent signals in real time: Customer Intelligence surfaces critical intent signals as they happen, giving LOs the superpower of knowing what borrowers and homeowners need when they need it.
  • Highlight life events as critical engagement opportunities: Customer Intelligence helps smaller lenders go beyond traditional intent signals, recognizing key life events or milestones (graduating, getting married, starting a family, changing careers, retiring, etc.) that signal shifting financial goals and new borrowing needs. This gives your LOs natural opportunities to reach out with helpful, personalized guidance.
  • Enable personalized outreach at scale and speed: Credit unions and community banks are using Total Expert Journeys and other automation capabilities to help their LOs stay on top of all of these valuable Customer Intelligence signals. Built-in triggers and automated Journeys enable LOs to magically engage at just the right time—across their full roster of customers and prospects.

Smaller lenders are leveraging Total Expert’s digital toolset to help them show up for borrowers when it matters most—across every and all channels—to give them the feeling they want most: a trusted financial advisor who understands their financial needs and goals, providing proactive support and guidance to help deliver the best possible outcome.

Measuring time-to-value in weeks, not years

Another major misconception among credit unions and community banks is that they don’t have the resources to manage this kind of automated, Customer Intelligence-powered strategy.  

It’s true that smaller lenders likely don’t have large internal teams of data analysts (if any). But Total Expert has led the charge in democratizing access to leading-edge data analytics tools and capabilities. We’ve designed Customer Intelligence and Journeys to be easy to deploy and quick and intuitive to set up.

The smaller size of most credit unions and community banks works to their advantage here. We consistently see these customers go live and start seeing measurable value with Customer Intelligence in as little as eight weeks because they’re able to implement, build, test, and launch faster than larger lenders that have more layers of reviews and approvals.

Smaller lenders driving big value: Customer Intelligence case studies

Dart Bank

  • Customer Intelligence in action: Dart Bank uses Customer Intelligence to surface life events and intent signals in real time, enabling LOs to engage members with proactive, personalized support across channels.
  • Driving measurable value: In just six months, Dart Bank drove an additional $48 million in funded loans—all by connecting with borrowers at the right moments of opportunity.

Tucson Federal Credit Union (TFCU)

  • Customer Intelligence in action: TFCU adopted Total Expert Journeys + Customer Intelligence to automate workflows, unify member data, and personalize communications; reducing manual work (e.g., uploading data daily) and streamlining email campaigns.
  • Driving measurable value: Open rates now exceed industry benchmarks (25–26%), and click‐through rates have improved. Campaign build times dropped from weeks to minutes.

Family Savings Credit Union

  • Customer Intelligence in action: Family Savings Credit Union moved from generic, outsourced marketing to using Total Expert Journeys, personalized messaging across channels, and better data visibility internally (bringing together core banking data, email, etc.), enabling them to send more strategic and relevant communications.
  • Driving measurable value: By acting on these insights, Family Savings Credit Union has increased retention and preserved the strong member relationships that fuel long-term success.

Horicon Bank

  • Customer Intelligence in action: Horicon created a Data Insights department, deployed Total Expert for centralized CRM/marketing automation, enabling more intentional targeting and personalized communications, letting staff have visibility into customer behavior across branches and channels.
  • Driving measurable value: The bank is now orchestrating timely, personalized borrower outreach at scale—transforming digital signals into relationship-building opportunities that strengthen loyalty.

Tech- and data-driven strategies have proven over and over that they have the ability to help deepen personal relationships for smaller credit unions and community banks. Our customers are proving that size doesn’t have to be a barrier. It can be an advantage that allows organizations to move quickly, leverage powerful tools like Customer Intelligence, and deliver authentic, personalized experiences at scale.

Learn more about Customer Intelligence and how it can drive consistent growth by enhancing your member and customer relationships.

Partner Ecosystem

[Dark Matter] Unlocking the Mortgage Ecosystem

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Total Expert’s Director of Product Integrations and Innovation, Mike Russell, recently joined Dark Matter Technologies’ Product Evangelist, Craig Rebmann, for an episode of Spotlight Backstage. Their conversation went behind the scenes of the mortgage ecosystem to show how lenders can drive real results by connecting the right people, processes, and technology to create a network of partners and integrations that streamline operations and create better borrower experiences.

From insights on how lenders are optimizing the technology they already use and adopting best practices to finding new ways to improve efficiency without sacrificing service, the key theme was clear: success comes from building a connected ecosystem where your tools talk to each other and your teams have the right support. If you want to see what’s possible when technology and partnerships align, this is the perfect place to start.

Catch the full conversation on Dark Matter Technologies' website >

Unlocking the Mortgage Ecosystem

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