With trigger leads going away, lenders who prepare will win

Federal legislation banning traditional mortgage trigger leads has cleared the Senate and is likely to be signed into law in the coming weeks. When that happens, lenders will lose a familiar — and often crowded — way to identify borrowers after a credit pull.

For some, that will feel like losing a trusted tool overnight. But in my 20-plus years in this business, I've seen that every major change creates an opening for those who adapt first. There's still a path to keep your pipeline healthy, your compliance team comfortable, and your competitors guessing — if you start making moves now.

The first step is to get clear on what's still permitted. While inquiry-based trigger leads will be off the table, the law leaves room to monitor borrowers when you have an existing, documented relationship. That includes situations where your company originated the borrower's current mortgage loan or is the current servicer, borrowers who've given you explicit consent, and customers of banks or credit unions with active accounts. Years ago, I learned the hard way that not knowing exactly who falls into those categories can cost you business. Now's the time to identify them — and get it on paper.

Next, make borrower consent a standard part of your process. Add opt-in monitoring language to every application, disclosure, and servicing touchpoint. I've seen lenders treat this as an afterthought — until they realize they've just lost sight of hundreds of in-market borrowers they could have legally monitored. That single adjustment will protect one of your most valuable data sources when the rules change.

Just as important — it's time to break the habit of relying on triggers alone. Triggers tell you a borrower is in the market only after they've applied somewhere else. Predictive monitoring changes the timing, flagging borrowers before they start shopping. When you combine those insights with listing alerts and equity monitoring, you can be in the conversation weeks or months before the other guy even knows there's a deal on the table. I've sat in meetings where this early reach made the difference between keeping a customer and losing them to a competitor.

Clean, accurate data will be your other advantage. In a tighter regulatory environment, you need to prove relationships quickly and without errors. That means scrubbing your CRM, validating origination data, and making sure every contact record is current. It's not glamorous work, but I've never seen a lender regret doing it.

And don't stop at defense. The lenders who come out ahead in the post-trigger era will be the ones using early borrower intelligence to grow — targeting markets where demand is building, re-engaging past customers before they drift away, and being first to make the right offer at the right time.

This isn't the end of borrower monitoring. It's a reset. A chance to move from chasing leads to building relationships before your competition even sees them. Lenders who take that shift seriously won't just survive this change — they'll own it.