Compliance & delivery standards
Compliance starts with clear campaign terms.
Clarity is operational, not decorative. Before a campaign launches, the terms should be written down in language both sides can inspect — and the buyer should understand its own obligations.
What a campaign summary should identify
A written campaign summary is the reference point for scope. Contents vary by campaign; the summary should state exactly what applies to yours.
- Buyer of record
- Permitted purpose
- Audience description
- Eligible states
- Lead type
- Delivered lead fields
- Source and consent artifacts, when applicable
- Secure portal transfer
- Portal access hours
- Volume caps
- Duplicate rules
- Replacement rules
- Price
- Cancellation terms
Buyer responsibilities
The buyer controls how leads are used, and is responsible for its own use of every lead, including but not limited to:
- Mortgage licensing and registration
- Permissible purpose determination
- Prescreen and firm-offer requirements, where applicable
- Call, text, and email law
- Federal and state Do Not Call screening
- Internal Do Not Call suppression
- Consent review and analysis
- Calling hours
- Caller ID and identification practices
- Recordkeeping and audit trails
- Vendor and subcontractor oversight
- Privacy and data security
- Fair lending practices
- Complaint handling and escalation
Comparative timing and pricing
TU Wholesale campaigns are designed to reduce the lead time associated with traditional bureau sourcing and are automatically priced to beat a materially comparable bureau campaign. Any timing or pricing comparison only applies where the campaign specifications are materially comparable — the same filters, volume, geography, records, documentation, and delivery terms.
Comparisons are not commitments. Actual timing depends on parameters, volume, source, geography, documentation, and availability, and the written order terms and campaign summary control scope, pricing, and delivery in all cases.
Phone append and enrichment
When a delivered record does not include a phone number, TU Wholesale can run phone-append enrichment and add a number when a reliable match is available. Match availability and accuracy vary, no match rate is promised, and an appended number does not guarantee that the record can be contacted.
Phone append does not itself establish consent, permissible purpose, Do Not Call clearance, or permission to call or text. The buyer must independently determine its permissible use and its calling, texting, suppression, licensing, and recordkeeping obligations before contacting any record.
Lead-service commercial structure
Compensation should be for bona fide advertising and lead-generation services at documented terms. It should not be contingent on closed loans, funded volume, or the selection of any settlement-service provider.
Pricing, delivery, and cancellation are set in the written order terms so the commercial relationship remains a services arrangement with clear deliverables.
No legal advice
Nothing on this page or elsewhere on this website is legal advice, and TU Wholesale makes no representation that any campaign, lead, or practice satisfies any particular law, rule, or regulator expectation. TU Wholesale does not claim any certification, approval, or compliance determination.
Have counsel review your campaign before launch.