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TU/Wholesale

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
  • Delivery method
  • Delivery 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
  • 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

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.