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Consent Management + Re-consent Workflow

Per-contact consent tracking with automatic re-consent gating when an LO changes employers. Built for the LOs who change shops every 4-6 years and don't want to inherit TCPA exposure with their book.

The data model

Every past-client contact in LO Radar carries three consent-related fields:

  • consent_basis — one of: originator-prior-relationship, borrower-volunteered, re-consent, inherited-with-employer-authorization, opted-out, unknown
  • consent_entity — the legal entity to which the consent was given. Typically the LO's employing lender at the time of origination (e.g., "First National Mortgage Inc.")
  • consent_date — the date the consent was given or last re-affirmed

When a past-client CSV is imported, contacts default to consent_basis='originator-prior-relationship' with consent_entity set to the LO's then-current employer. This reflects the standard origination-consent framework: borrowers consenting to loan servicing and related communications from the originating institution.

The re-consent trigger

The re-consent workflow fires automatically when:

  1. The LO updates their current employer in Settings → Account → Employer
  2. The new employer differs from the consent_entity stored on one or more past-client contacts
  3. The contact's consent_basis is originator-prior-relationship (the most common case where re-consent applies)

For affected contacts, LO Radar:

  • Tags the contact with status "Re-consent required"
  • Gates standard outreach drafting until re-consent is captured
  • Surfaces the TCPA-safe re-consent first-touch template (below) as the only available outreach
  • Logs the re-consent gate event to the audit log

The TCPA-safe re-consent template

The first-touch template explicitly acknowledges the LO's employment change, names both the prior and current employer, and asks the borrower to confirm preferences. The template is informational — no rate quote, no commercial pitch.

Sample template — email
Hi [Borrower First Name], Quick housekeeping note — I wanted to let you know that since we worked together on your mortgage at [Prior Employer Name], I've moved to [Current Employer Name]. I'm still licensed and still here when you need a mortgage question answered. Before I send you anything else, I want to make sure you're okay with that. If you'd like me to keep you in the loop on rate and refinance opportunities going forward, just reply with a thumbs-up (or say "yes, keep me on the list"). If you'd rather I stop reaching out, reply STOP or "remove me" and I'll permanently remove you from outreach — no offense taken. Either way, thank you for the original business. Hope you and the family are well. — [LO First Name] [LO Name], NMLS #[NMLS ID] [Current Employer Name] [LO Phone] · [LO Email] To opt out of future emails, reply STOP or click [unsubscribe link].

The SMS variant is similarly informational and explicitly opt-in-requesting; it carries the required STOP / HELP instructions and the LO's NMLS identifier per state-level mortgage advertising rules. The SMS template is generated by the State Disclosure Engine using the borrower's state-of-residence and the LO's NMLS licensed states.

What happens after the borrower responds

Three outcomes are supported:

(a) Opt-in (affirmative response). The LO records the response (manual entry or, on Enterprise, automatic detection from the LO's connected inbox). The contact's consent fields update to consent_basis='re-consent', consent_entity=[Current Employer], consent_date=[today]. Standard outreach drafting unlocks immediately. The audit log records the opt-in.

(b) Opt-out (STOP / "remove me" / negative response). The contact updates to consent_basis='opted-out'. Outreach drafting is permanently gated. Internal DNC list updates. The audit log captures the opt-out timestamp and channel.

(c) No response (default after 30 days). The contact remains in "Re-consent required" status indefinitely. The LO can manually escalate via phone or in-person conversation; if successful, the LO captures the verbal consent in LO Radar (with date and channel for audit) and the contact unlocks. Without affirmative re-consent, the contact stays gated to outreach.

Why this is the right TCPA posture

TCPA exposure for mortgage LOs concentrates in two scenarios:

  • Auto-dialed or pre-recorded contact without prior express written consent. LO Radar does not auto-dial and does not send messages on the LO's behalf — drafts are sent from the LO's own systems, manually, which keeps these out of the autodialer-consent framework.
  • Contact to a past borrower after the LO has left the originating entity, where the original consent was tied to that entity. This is the scenario the re-consent workflow specifically addresses. Without it, an LO who changes employers inherits TCPA exposure with their book — the consent given to Lender A doesn't automatically transfer to outreach from the LO at Lender B.

The re-consent workflow makes the TCPA posture clean by ensuring every commercial outreach has an unambiguous consent record traceable to the current sender entity. The audit log makes that record defensible.

Integration with the Branch Compliance Dashboard

At the branch level, the compliance officer can audit consent status across all LOs in the branch. The Branch Compliance Dashboard surfaces:

  • Count of contacts in each consent state (originator-prior-relationship, borrower-volunteered, re-consent, opted-out, unknown)
  • Count of "Re-consent required" contacts per LO
  • Re-consent completion rate per LO over time
  • Recent opt-outs across the branch

This gives the branch supervisor the visibility expected under NMLS employer-supervision responsibilities without exposing the underlying past-client PII to the compliance officer.