Compliance Overview

LeadFi is fully aligned with FTC, FCRA, TCPA, and related data protection standards. We operate strictly as a secure pass-through system and do not store consumer credit data. All credit-related information is encrypted in transit and processed only for eligibility determinations.

FCRA Prescreening & How LeadFi Fits

Under the Fair Credit Reporting Act (FCRA), prescreening—offering credit or insurance based on information in consumer reports—can be conducted without prior consumer consent, provided specific conditions are met.

Key FCRA Provisions Allowing Prescreening Without Consent

  • Permissible Purpose (§604(c)): Prescreening is allowed if the offer is a “firm offer of credit or insurance” and the entity has a legitimate FCRA-defined reason to access consumer reports.
  • Firm Offer of Credit or Insurance (§603(l)): A “firm offer” must be bona fide and honored if the consumer meets pre-established criteria. It cannot be a solicitation only.
  • Opt-Out Notice (§615(d)): Consumers must be clearly informed of their right to opt out of prescreened offers, with a toll-free number or website provided.
  • Use of Consumer Information (§604(c)(2)): Data obtained through prescreening can only be used to make the firm offer, not for unrelated marketing.
  • Regulatory Guidelines (16 CFR Part 642): The FTC requires opt-out notices to be simple, clear, and easy to understand.

Summary:

Prescreening without prior consent is permissible if:

 

  • The offer is a firm offer of credit or insurance.
  • Consumers are informed of their right to opt out.
  • Consumer data is used only for the offer.

How LeadFi Mirrors TransUnion’s FastScreen® Model

 

LeadFi’s technology follows the same framework as TransUnion’s FastScreen®, a well-established FCRA-compliant prescreening system used by major credit issuers.

 

 What FastScreen® Does:

  • Uses soft credit data to match consumers against pre-set criteria.

  • Returns a simple thumbs-up/thumbs-down result—never a full report.

  • Enables businesses to send firm offers of credit to qualified consumers

  • Operates under the prescreen exemption in FCRA (§604(c), §603(l)).

This is why consumers receive pre-approved credit card offers in the mail: prescreening allows it, without prior opt-in.

 

How LeadFi Works the Same Way:

  • A consumer fills out a standard opt-in form (no credit checkbox required).
  • LeadFi’s algorithm processes the data against financing criteria.
  • No personal credit data is stored, viewed, or shared.
  • The business receives only a binary result (eligible/ineligible).
  • If eligible, the consumer may receive a firm financing offer.

Because LeadFi never exposes trade line data, PII, or regulated report details, and only returns a binary eligibility response, it remains fully compliant under the same legal principles that govern FastScreen®.

 

Client Compliance Requirements

To remain compliant while using LeadFi, clients must complete the following:

 

  1. FCRA-Compliant Privacy Policy Language (Mandatory)
  • You must include FCRA-compliant prescreening language in your privacy policy (Provided by LeadFi).

  1. TCPA Compliance (Mandatory)
  • You must follow the Telephone Consumer Protection Act (TCPA).
  • TCPA requires prior express written consent before contacting consumers by phone, text, or autodialer.
  • Consent must be clear, unambiguous, and documented.
  • Non-compliance can result in significant penalties.

     

  1. Optional TCPA Checkbox Language
  • You may add an extra checkbox at the point of consent (Provided by LeadFi).
  • This is not legally required but provides additional clarity and protection.
  • Considered best practice to remove ambiguity and demonstrate proactive compliance.

     

By completing steps 1 and 2, you are compliant. Adding step 3 is considered very conservative and demonstrates proactive risk management.

 

Privacy & Data Security

 

  • Privacy: Refer to our full Privacy Policy.
  • Data Security: LeadFi maintains rigorous safeguards but does not store consumer credit data. We serve only as a secure pass-through between your system and credit providers, ensuring minimal exposure and maximum compliance protection.