1.What Are Mortgage Trigger Leads?

Mortgage trigger leads are generated when a consumer applies for a mortgage and their credit report is pulled by a lender. That credit inquiry is then sold by credit bureaus to other lenders, who use it as a signal to reach out to the consumer with competing offers. While this practice is legal under federal law, it has drawn criticism for creating confusion, leading to unsolicited calls, and enabling misleading sales tactics—particularly when consumers mistake the outreach for a follow-up from their original lender.

2.What HB 240 Prohibits

Georgia’s new law makes it an unfair or deceptive practice to use trigger lead data to contact consumers without meeting certain standards. First, any lender or broker contacting a consumer must clearly disclose that they are not affiliated with the lender to whom the consumer originally applied. Failure to do so may now be considered a deceptive business practice under state law.

The law also requires compliance with federal prescreening rules, including the Fair Credit Reporting Act’s requirement to make a firm offer of credit when using prescreened consumer data. Georgia now prohibits solicitations sent to consumers who have opted out of prescreened offers or who are listed on the National Do Not Call Registry. In addition, the law bans bait-and-switch tactics—such as quoting specific rates or terms in an initial offer and then changing those terms once the consumer engages with the lender.

3.Why It Matters for Mortgage Professionals

Mortgage lenders, brokers, and marketing partners operating in Georgia must adjust their marketing practices immediately. Any solicitation that arises from credit trigger data must be transparent and comply with both state-level and federal requirements. That includes verifying opt-out status, including proper disclosures, and ensuring that any offer made is firm and compliant.

Violations of HB 240 may be enforced under the Georgia Fair Business Practices Act, which allows for civil penalties, injunctive relief, and potential consumer claims.

4.Effective Immediately

Unlike many new laws that take effect months later, HB 240 became effective immediately upon enactment on May 13, 2025. This leaves no grace period for lenders who may be using trigger leads in their marketing pipelines—compliance must begin now.

If you market in Georgia using credit bureau-sourced leads or work with third parties who do, now is the time to conduct a compliance check and ensure your practices align with the new law. We’re happy to help with policy reviews or to assist your team in updating disclosures and procedures.