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Credit Reporting Agencies (CRAs) collect consumer data, such as names, addresses, social security numbers, credit histories, and public information, then compile that information into consumer credit reports. CRAs also use this information to develop proprietary credit scores or share that information with entities that develop credit score models, which indicate a consumer’s propensity to repay a loan.
A “trigger lead” is a marketing product that CRAs sell to third parties when a lender initiates a hard credit pull for a prospective mortgage applicant. Trigger leads are used to create competing offers for the future homebuyer. ICBA strongly supports legislation that would limit trigger lead solicitations exclusively to mortgage applicants who provide their consent or lenders that have previously originated a mortgage for the applicant, capturing refinance activity; lenders currently servicing the mortgage; or insured depository institutions that have a current account with the applicant.
The CFPB has finalized a rule that would eliminate the inclusion of medical debt in credit reports. The Bureau has also proposed a rule that would require any company that collects and sells consumer data to be covered by FCRA, potentially limiting the ability for third parties to buy trigger leads from CRAs.