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Financial Services Law Insights and Observations

Vermont Law Regulates Disclosures for Trigger Lead Solicitations

State Issues

On May 10, Vermont Governor Jim Douglas signed HB 622, which will require increased disclosures for mortgage loan “trigger lead” solicitations. The legislation requires that solicitors disclose (i) that they are not affiliated with a consumer’s financial institution, (ii) that the financial institution did not supply the consumer’s personal or financial information, and (iii) who will be paid for the trigger lead. The bill authorizes financial institutions that are misrepresented through a trigger lead solicitation to bring an action against the solicitor for damages and attorneys’ fees. The law will take effect July 1, 2010.