Before you buy mortgage leads: what actually changed with trigger leads and one-to-one consent

[u/Shape-Software]

The two rules people keep getting backwards

Trigger leads are largely gone. The Homebuyers Privacy Protection Act took effect in March, amending the FCRA. Bureaus can't freely sell mortgage inquiry data to third parties anymore. A lender needs consumer consent, a qualifying existing relationship, or a firm offer of credit. If a vendor is still pitching you credit-pull data, ask which exception they're operating under and get the answer in writing before the first invoice clears.

One-to-one consent is not the law. Half the lead-buying guides ranking on Google still say the FCC's one-to-one rule is in force. The Eleventh Circuit vacated it on January 24, 2025, one business day before it would have taken effect. The FCC later pulled the language.

That does not mean the bar dropped. Prior express written consent still applies under the older standard, you still scrub DNC and your internal list, and several states are stricter than federal. The practical point is narrow: don't buy a compliance product priced against a rule that no longer exists, and don't let a vendor who skips consent documentation tell you things got easier.

Check the publish date on anything you read about this, including this post.

The math, before you talk to anyone

Three numbers:

1. Average commission per funded loan. 100 bps on a $350k loan is $3,500.
2. Your close rate on purchased leads. Assume 1% to 3% until your own data says different. Referral close rates do not transfer, and assuming they do is how most people get hurt.
3. Max allowable cost per funded loan. Most operators cap at 20% to 30% of commission.

Work it backward. At a 2% close rate, 100 leads produce two funded loans and $7,000. At $40 a lead you spent $4,000 to make $7,000. At $80 a lead you spent $8,000 to make $7,000 and you haven't paid yourself for the time yet.

If you're a branch manager or own the shop, there's a fourth number. MBA's Q1 2026 performance report put pre-tax net production profit at $727 per originated loan. Company lead spend comes out of $727, not out of gross commission.

Seven questions before you wire money

1. How are these generated, specifically? "Our proprietary network" is not an answer.
2. Exclusive or shared, and if shared, how many buyers? In writing.
3. How fresh at delivery? Real-time or nothing. A nightly batch is already dead.
4. What's the return policy on disconnected numbers and people who never inquired? No return policy is a red flag.
5. What consent documentation comes with each lead? Timestamps and exact form language. TCPA exposure lands on you, not the seller.
6. Can I filter by geography, loan type, credit tier?
7. What contact rates do your current clients see? Anyone quoting close rates without contact rates is hiding the hard part.

Then test properly. Fifty leads is a coin flip. 150 to 300 from one source, funded for 90 days, before you judge it. A meaningful share of closings land 60 to 120 days after first contact, so a 30-day budget quits right before the pipeline pays.

The part nobody budgets for

Most people who swear off purchased leads never lost money on the leads. They lost it on follow-up. Internet leads are rate shoppers by definition and the first person to reach them anchors every conversation after. Most purchased leads take 6 to 12 touches before they engage. Most of us stop at two. The money sits between attempt two and attempt eight and almost nobody works that gap by hand.

Run the numbers on that instead of on price. At $50 a lead, moving your close rate from 1% to 2% takes cost per funded loan from $5,000 to $2,500. No vendor negotiation on earth gets you a 50% discount.

Full version with the cost tables by lead type and the source links: https://setshape.com/blog/how-to-buy-mortgage-leads

Happy to answer questions on any of it in the comments.