Mortgage broker leads: calling online enquiries fast and following up the right way

When someone fills in a form on your website asking about a home loan, you can usually phone them back to talk about mortgage products, even if their number is on the Do Not Call Register. The Do Not Call Register Regulations use almost exactly this situation as an example. It only works if you call about what they asked for, call within a reasonable time, and stop when they withdraw the request. The harder part is what happens when the enquiry goes quiet. This article covers both: how to call new mortgage broker leads quickly, and how to keep following up without drifting into calls you no longer have permission to make.

The Regulations' own mortgage broker example

Brokers rarely get a regulation written so closely around their work. The Do Not Call Register Regulations 2017 give the example of a person who fills in an online form on a mortgage website asking for more information, and a mortgage broker who then phones that person to discuss mortgage products.

The example illustrates a wider rule. Under the Do Not Call Register Regulations 2017, a call is not a telemarketing call if it responds to a customer's or potential customer's order, request or inquiry about goods or services, is mainly about that request, the request has not been withdrawn, and the call is made within a reasonable time.

So the person who asked about refinancing through your website hasn't simply given you a number to call whenever you like. They've asked you a question, and your call is the answer. While the call stays an answer to that question, it is a solicited call, not telemarketing.

What keeps the call a solicited call

All of the conditions have to hold together. Each one is a place where a broker's process can slip.

The call is mainly about what they asked

If someone asked about a first home loan, talk about their home loan: their borrowing situation, the documents you'll need, a time to meet. It's natural to mention related things. But if the call turns into a pitch for insurance, a different product or a referral partner's services, its main purpose is no longer their request. Script the opening so it names the enquiry clearly, for example "You asked on our website about refinancing your home loan".

The request hasn't been withdrawn

If the person says they've sorted their finance elsewhere, or simply that they don't want to hear from you, the request is gone. On consent more broadly, the Do Not Call Register says that if a consumer indicates they do not want telemarketing calls from an organisation, consent ends immediately and can no longer be inferred. Your CRM needs an obvious way to record this. Every caller, whether a person or an AI agent, should treat it as final.

The call is made within a reasonable time

The Regulations don't turn "reasonable time" into a fixed deadline, so don't assume you have weeks. Plainly, a call that comes soon after someone asks a question is a response to it. A call that arrives long after they've stopped thinking about it looks more like marketing. If you're unsure how long is too long for your situation, check with the ACMA or a lawyer.

A note on bought or shared leads

The Regulations' example describes a person who filled in a form on a mortgage website and a broker who phoned them. If your leads come from a comparison site, an aggregator or a referral partner, ask who the person actually made their request to and whether that request covers you. Get advice before you rely on the solicited-call exception for leads you didn't capture yourself.

Why speed is the whole game with online enquiries

Speed matters for compliance, and it matters just as much for converting the lead. Someone researching a home loan online is often doing it in a spare moment, comparing several options. While they're still at their desk or holding their phone, they remember filling in your form and they're ready to talk. Later in the day they're busy, and they may have spoken to someone else by then.

Practical ways to shorten the gap:

• Route web enquiries straight to a phone queue, not a shared inbox someone checks after lunch.
• Decide who owns new enquiries at each hour of the business day, including during client meetings.
• Keep the opening call short: confirm the enquiry, ask a few qualifying questions, and book a proper appointment.
• Send a confirmation message after booking, so the appointment doesn't rely on memory.
• Watch the time between form submission and first call as an operational measure, not just conversion.

Respect calling hours too. Under the telemarketing industry standard, calls outside its permitted times are allowed only if the account holder or their nominee gave express consent in advance to that particular call on that day or at that time, and the caller can show this to the ACMA if required. If someone enquires late at night, the safest course is usually to call at the start of the next permitted window, unless they've specifically asked to be called at a particular time and you've recorded it.

When the enquiry goes quiet

This is where most broker follow-up gets risky. The person enquired, you called, perhaps you left a voicemail or had a brief chat, and then nothing. As time passes, it gets harder to describe a new call as a response to their original request made within a reasonable time. At some point you need a different basis for calling, and that basis is consent.

Ask for express consent on the form itself

Under the Do Not Call Register Act 2006, consent means express consent, or consent that can reasonably be inferred from the person's conduct and their business and other relationships. Inferred consent is a judgement call. Express consent is much easier to defend.

The ACMA recommends express consent based on clear terms and conditions, readily accessible where consent is given, that explain what the marketing is for, who will use it, how long it will be used and how consent can be withdrawn. For a broker's enquiry form, that means a separate, clearly worded checkbox, not a line buried in a privacy policy.

The ACMA also says businesses should not use pre-checked tick boxes, bundled consent or refer-a-friend arrangements to obtain marketing consent. Leave the box unticked, keep it separate from agreeing to your privacy terms, and don't use a "refer a friend who's buying" field to collect someone else's number for calls.

Remember that a phone number in a public listing doesn't give you permission either. Under the Do Not Call Register Act 2006, consent to telemarketing calls cannot be inferred merely because a phone number has been published.

Keep the consent record with the lead

The ACMA expects consent records to show how consent was obtained, the terms that applied, and the date and time it was obtained, and those records must be produced if the ACMA requires them. In practice, store with each lead:

• The form or page it came from.
• The exact consent wording shown at that time.
• Whether the consent box was ticked.
• The date and time of submission.
• Any later opt-out, with its date.

If your website form changes, keep the old wording. A record that says "consented" without showing what they agreed to is weak.

Watch the 3-month mark

This is the date many follow-up campaigns overlook. Under the Do Not Call Register Act 2006, express consent that is not given for a specified period or an indefinite period is taken to be withdrawn 3 months after the day it was given. The ACMA's guidance similarly says that consent more than 3 months old becomes stale unless the consumer agreed to a longer period under terms and conditions.

For brokers, home loan decisions often take longer than that. A buyer may enquire, go quiet while they save or search, and be ready months later. If you want to keep calling past 3 months, your consent terms need to say so clearly when the person agrees. Otherwise, build your follow-up so it ends, or switches to asking for fresh consent through a permitted channel, before the consent lapses. Whether a longer period is appropriate for your business is worth checking with a lawyer.

A sensible follow-up rhythm

Without inventing a formula, a follow-up sequence for quiet mortgage enquiries usually looks like this:

• Prompt calls while the enquiry is fresh, at varied times within permitted hours.
• A short message saying you tried to call and how to book directly.
• Spaced check-ins tied to what they told you, such as their settlement timing or a pre-approval expiring.
• An automatic stop once consent expires or the person opts out.

Each call should still sound like a continuation of their enquiry, not a cold pitch.

Questions to ask before you scale follow-up

• Does every form that collects mortgage broker leads have unticked, separate consent with plain terms?
• Can we produce the consent wording, date and time for any lead on request?
• Does our CRM automatically flag leads approaching 3 months since consent?
• Is an opt-out recorded instantly and respected across every caller and channel?
• Do our calling tools refuse to dial outside permitted hours unless a specific time was agreed?
• For bought or referred leads, have we had advice on whether we can call them?

Where an AI voice agent fits

Speed and consistency are hard to deliver with a busy broker team, which is why many firms are looking at automation for the first call. Dialessa is an AI voice agent that calls new enquiries within a minute, books the appointment into your calendar, and follows up past leads whose consent is still current. Whatever tool you use, the rules above still apply: call about what they asked, record consent properly, honour opt-outs and stop when consent runs out.

If any part of your process sits in a grey area, especially consent periods or third-party leads, check with the ACMA or a lawyer before you scale it.