Privacy Law Library

Homebuyers Privacy Protection Act

HPPA

Credit reporting · Marketing · Financial

This 2025 law limits 'trigger leads', which are credit reports sold to other lenders when a consumer applies for a mortgage. From March 4, 2026, an agency may pass on such a report only for a firm offer of credit or insurance to a party that has the consumer's documented consent or already originates, services, or holds an account relationship with the consumer.

Where
Federal
Citation
Pub. L. 119-36 (Sept. 5, 2025); 15 U.S.C. 1681b(c)(4)
Status
In force
In force since
2026-03-04
Enforced by
CFPB and FTC (through FCRA enforcement), plus FCRA private actions
People can sue
Yes
Penalties
Violations are FCRA violations: willful noncompliance allows actual or $100-$1,000 statutory damages plus punitive damages and fees; regulators may also enforce.
Applies to
  • Consumer reporting agencies that receive residential mortgage credit inquiries
  • Third parties seeking prescreened 'trigger lead' lists tied to mortgage inquiries

Practices it requires

  • Do not furnish a mortgage-inquiry-triggered consumer report to another person unless the transaction is a firm offer of credit or insurance.15 U.S.C. 1681b(c)(4)(B)(i) · From 2026-03-04
  • The recipient must certify it has the consumer's authorization, or be the consumer's current mortgage originator or servicer, or an insured depository institution or credit union holding a current account for the consumer.15 U.S.C. 1681b(c)(4)(B)(ii) · From 2026-03-04

Sources

Checked against these sources on 2026-09-25 by research agent (Claude), primary sources.

Unverified: The effective date (180 days after Sept. 5, 2025) was computed as March 4, 2026 from the statutory note

Research reference, not legal advice.