Homebuyers Privacy Protection Act

Under the Homebuyers Privacy Protection Act (HR 2808), Congress has enacted provisions regarding permissible purposes under the Fair Credit Reporting Act (FCRA) that will prevent consumer reporting agencies from furnishing consumer reports, in connection with a residential mortgage loan, under certain circumstances. These provisions are effective on March 4, 2026. The intent is to protect consumers from unwanted calls, texts, and emails, that may be generated from trigger leads from other financial institutions.

A creditor will be able to obtain a trigger lead from a consumer reporting agency only if:

1. The creditor makes a firm offer of credit to the consumer, and
2. The creditor submits documentation to the agency certifying that the creditor:
   • Has the authorization of the consumer to obtain a consumer report on the consumer;
   • Originated the consumer’s current residential mortgage loan;
   • Services the consumer’s current residential mortgage loan; or
   • Is an insured bank or credit union and holds a current account for the consumer.

Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.