Have you ever considered buying leads from a non-profit, consumer advocacy referral service? Consumer advocacy? Ha! These lead companies are trying to sell consumers information at the end of the day but are disguising their efforts as a service to help seniors. These services are highly suspect as to whether they are soliciting loans from consumers as they are collecting personal information and distributing it to one or many different clients purchasing that information.
I asked one of these companies about their licensing status and that asked me what I was talking about… which shocked me… should these services be licensed entities? These companies should be subject to the same patchwork of unorganized and complicated state regulation unless they are a division of a federally chartered bank. They are soliciting information for the purposes of someone originating a loan. There is one large lead service that employs a celebrity spokesperson and that firm has taken the time to license properly and has the disclosures on their television and print advertisements. In my opinion, this is the most compliant lead service I have seen to date. While it may have taken a long time to get the infrastructure setup, it is the proper format. If you buy leads from a company that publicly collects information and resells that you should not only check to see how they are marketing, advertising and collecting that information but you should ask if they are licensed to originate loans in that particular area. If they say they don’t need to be licensed, you are probably dealing with an ignorant lead and non-compliant, unlicensed loan origination operation. As my good friend and legal counsel would say, “Govern yourself accordingly.”
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