Lending

Navigating New Trigger Lead Rules: The Total Expert Advantage

5 mins read
July 14, 2025
By
Mike Waterston

The U.S. House of Representatives recently passed H.R. 2808, also known as the Homebuyers Privacy Protection Act (HPPA), which is designed to curb the abusive practice of “trigger leads.” The House and Senate still need to reconcile the bill before final approval (we fully expect it to pass), but the mortgage industry is already buzzing about how this might limit prospecting and lead generation strategies.

Total Expert already gives our customers fine-grained controls to comply with this proposed legislation. The HPPA only affirms the relationship-driven strategies already proven by leading lenders—the kind Total Expert was built to enable and enhance.

Here’s everything you need to know about this proposed legislation:

What is the “trigger leads” ban?

Trigger leads occur when a consumer applies for a mortgage, triggering an inquiry to a credit reporting agency (CRA), which then sells that consumer’s contact information to other lenders—often without that consumer’s knowledge or explicit consent. The lenders that purchase these trigger leads then use them for lead generation campaigns. For the consumer, this often means a barrage of unwanted calls, texts, and emails.

HPPA would to restrict the sale and use of these trigger leads, prohibiting CRAs from selling (or otherwise “furnishing”) consumer reports related to residential mortgage transactions—with a few key exceptions.

The larger goals are to protect consumer privacy and reduce predatory practices that undermine trust. The more immediate goal is to ensure that consumers applying for a mortgage aren’t immediately subjected to a deluge of unsolicited offers from unknown lenders that mislead borrowers and create significant confusion.  

What is permitted under the proposed law?

As currently written, HPPA leaves room for trigger leads to be purchased and leveraged by lenders if they fit into one or more of the following categories:

  • The lender has originated the current residential mortgage loan of the consumer to whom the consumer report relates
  • The lender is the servicer of a current residential mortgage loan of the consumer to whom the consumer report relates
  • The lender is an insured depository institution or credit union AND holds a current account for the consumer to whom the consumer report relates.  
  • The lender has obtained consent from the consumer and can provide documentation of such consent to a credit agency if needed.

The common theme here is that these are all situations where the lender has either an existing business relationship with the consumer or has received explicit consent from the consumer to be monitored by the lender.

What does HPPA mean for Total Expert customers?

We built the Total Expert platform to help our customers make more genuine human connections and build authentic, lasting relationships. No good relationship ever started with unwanted badgering, so fully respecting consumer consent and privacy was a foundational priority from Day 1 at Total Expert.

More to the point, we designed the Total Expert platform to balance automation with granular control—to make sure you’re talking to the right people at the right time. Our built-in safeguards already prioritize responsible engagement. These controls ensure you’re only engaging with individuals with whom you have an existing relationship, or those who have explicitly opted into communications from you. This means:

  • You’re focusing on truly high-value opportunities. You can use Total Expert to identify and nurture leads where a foundation of trust or clear interest already exists.
  • You’re deepening existing relationships. You can lean on Total Expert’s Customer Intelligence and journey orchestration to engage your members and customers with relevant, timely offers, rather than endlessly chasing cold leads.  
  • You’re building trust, not jeopardizing it. By respecting privacy and giving you insights and tools to engage thoughtfully, we’re helping you reinforce your brand reputation and foster trust that defines long-term loyalty.

What’s next?

We’re closely monitoring the status of the HPPA. We will continue to support our customers in navigating and complying with any new requirements that emerge as part of this proposed legislation. We’re committed to giving you the tools and guidance you need.

But in a broader sense, this legislation doesn’t change the best practices we’ve always preached. And it shouldn’t change the relationship-driven strategies our customers have developed through the Total Expert platform. Instead, this is a clear signal to double down on engaging with precision, relevance, and (above all) genuine respect for your customers and members. That’s how you win customers for life!

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If you still view artificial intelligence as some unrealized, head-in-the-clouds, “I’ll believe it when I see it” concept, you’re already behind the times. That's exactly what we discussed on a recent episode of Lykken on Lending, where our own Mike Russell (Director of Product Integrations and Innovation at Total Expert) and Assurance Financial's Jessica Thames (Director of Marketing) sat down with David Lykken to explore how AI is already reshaping the way lenders engage with borrowers, manage outreach, and scale their business without sacrificing the human connection at the heart of the industry.  

For many loan officers, the idea of letting an AI talk to their customers understandably raises some eyebrows. After all, how is a machine supposed to replicate (or even replace) the kind of conversation that people have with a trusted professional? But as our conversation demonstrates, that’s not the goal of mortgage-specific AI tools. Instead of replacing loan officers, tools like Total Expert’s AI Sales Assistant empower them to focus on what humans do best: build relationships, provide guidance, and help customers make important financial decisions with confidence.  

Part of our conversation focused on the evolution from generic chatbots to AI-enabled automated outreach. Where chatbots followed a rigid script and were confined to specific “yes/no” or “if this, then that” workflows, AI-enabled assistants are able to engage in more dynamic conversations, react to unscripted questions or challenges, and become an extension of a lending team. For example, by leveraging data from Total Expert Customer Intelligence, our AI Sales Assistant can act on intent signals like credit improvement, rate drops, or equity thresholds that might otherwise go untouched. Loan officers can only make so many phone calls or emails in a given week, but an AI Sales Assistant can engage multiple opportunities simultaneously and won’t get discouraged if they don’t get an immediate response.  

Perhaps the most compelling part of the conversation came from the real success stories shared. Mike explained how early pilots showed real results within weeks, transforming difficult-to-convert leads into appointments that a loan officer could close, without manually dialing dozens of times. Jessica also highlighted how being freed from low-value tasks allowed her team to concentrate on delivering meaningful borrower interactions — and that this shift is fundamentally what AI should be about.

David, Mike, and Jessica also tackled the elephant in the room: the fear of AI replacing people. Rather than seeing AI as a threat, both Mike and Jessica frame it as a force multiplier that enhances productivity, enriches human jobs, and lets loan officers do more in less time. Mortgage professionals already use automated tools for things like email sequences or text triggers, but AI can’t replace our ability to empathize with a borrower who has credit challenges or a homeowner who needs a HELOC to help pay for urgent repairs. AI can only help you show up for more customers in the moments that matter.

The episode also dives into practical considerations like compliance, data quality, and best practices for implementation by giving listeners a grounded understanding of not just why AI matters, but how to make it work in real mortgage environments.

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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!

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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.

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