The Lead Generation Company: Managing the Risks

 Commentary and Analysis


Paper and Article

February 24, 2015








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You may be interested in reading my recently published paper, entitled "The Lead Generation Company: Managing the Risks."


My firm often is requested by clients to vet a lead generator. 


Careful risk management advice should be considered when developing and managing leads, whether obtained from an outsourced entity or a loan originator's own website, in-house, or through online lead generation advertisements. 


Certainly, any loan originator that uses leads must have an internal compliance function that accounts for proper licensing of the Lead Generation Company (where required), monitoring of the data integrity derived therefrom, testing conformance with the originator's policies, and training of staff in the appropriate use of lead generated, consumer data. 


In this paper and article, I discuss the four rules of lead generation marketing, plus insights regarding regulatory focus, consumer advocacy, lead generation as advertising, the three concerns about online lead generation companies, the scope of reviewing a lead generation company, and planning for a visit from the CFPB. 


The article is published in the February 2015 edition of National Mortgage Professional Magazine.


I hope you find the paper informative!



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Generating leads is an important way to reach consumers. It is also fraught with regulatory risk. A lead is consumer information that signals consumer interest or inquiry into products or services offered by a business, such as residential mortgage lenders and originators. 


There are several factors to be considered, not just licensing. I will list some rudimentary guidelines in this article, specifically with respect to contact with the consumer. 

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The Bureau reviews advertisements and advertising sources. 


It will review TV, radio, print media, Internet, scripts, recordings, and so forth. It will determine if there was proper consumer disclosure all along the way, from point of contact with the consumer to point of contact with the lender, including any intimation of fees and other terms and conditions.


Plus, a review is conducted for online data security and sharing of consumer information. 

Lenders Compliance Group of Companies are the first mortgage risk management firms in the United States that provide professional guidance and support to financial institutions in all areas of residential mortgage compliance, including the following: Mortgage Acts & Practices ● Legal and Regulatory Compliance ● Forensic Mortgage Audits ● HUD Exam Readiness ● Licensing Compliance ● HMDA/CRA ● Information Technology & Security ● Portfolio Risk Management ● Quality Control Audits ● Prefunding Audits ● Retail, Wholesale, and Correspondent Platforms ● Broker and TPO Compliance ● Investor and Servicer Compliance ● Loss Mitigation Strategies ● Marketing Compliance ● Due Diligence ● Credit Risk Management ● Loan Analytics Audits ● Compliance Audits ● Banking Exam Readiness ● GSE Applications ● Ginnie Mae Applications ● Training & Education ● CFPB Exam Readiness ● Anti-Money Laundering Program Compliance ● TPO Approvals ● Vendor and Service Provider Compliance. 

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