Some time back we published an article that detailed widespread non-compliance in the Australian Financial marketplace by way of unsolicited offshore lead generation. After an internal investigation we traced the source to a Sydney-based broker that generally was not aware of the unscrupulous practices employed by the New-Delhi-based BuyMyLeads service. In order to cast a wide net and attract leads for a group of brokers rather than just one individual business, the offshore service would use an existing business as a placeholder; at the time this was Astute Financial and Nexus Money - both very reputable businesses that were in no way connected to the telemarketing calls.

In recent times I've received a new wave of these calls all over again - often daily. In most cases, once they figured I was probing for too much information they'd simply hang up; at other times I'd make a booking to see a broker and play dumb in order to follow through and identify the upline local source.

A short time back I met with a broker in Western Sydney and quickly learned that he was provided with my details via a Facebook Group managed by a Brisbane-based "marketer" that was using the offshore service to supplement his poor-performing Facebook program. In a meeting with the first broker I quickly learned that while the Brisbane marketer was providing 'free' leads to a Facebook group, he would often use 'leads' squeezed from these call centers in order to meet a minimum number of leads he guarantees to clients (the same guy routinely pops up on our radar for his rather deceptive approach to financial marketing). In order to definitely determine the source we met with three other brokers over as many weeks who all provided the same information (with one other marketing company making its way into the mix).

If you didn't generate a lead yourself, or it wasn't served via an established and supported local network, then it is not an ethical lead. It could be argued that if you're aware of a questionable lead source then you're complicit in an offence (in our case the upline source is objectively breaking the law in order to make a booking). A marketing company assists a business in generating their own leads... not by delivering misguided leads that were fraudulently persuaded into an appointment (without knowing who they'd actually booked an appointment with).

I need to make one point clear that I would have thought most brokers would be familiar with: advertising Financial services is heavily regulated, appropriate licences must be held, and no unsolicited (and certainly no deceptive) calls are permitted in order to 'sell' a mortgage. Marketers do not have a Financial Services Licence, we do not hold our own Credit Licences (although we soon will), and we are not an Authorised Representative... so we are generally not permitted to generate a pool of finance leads ourselves (I say 'generally' because we do have online aggregation-style websites and highly positioned lead generation services for our clients but they're always supported by a qualified broker, leads are never given away or auctioned off, the platforms are always in full compliance with legislation, and we always liaise with aggregators to ensure we have their full support).

If you've ever received a free lead then the individual providing you with that source was likely complicit with criminal conduct. The telemarketing practice employed to garnish these 'leads' violate about every piece of financial legislation ever written - it must stop now. In the wake of the Royal Commission , in particular, there's no excuse for participating in any program as we've described. Part of the responsibility inherited by guys like us is to provide an individual marketing experience that is fully compliant with relevant legislation and other industry regulations. Sadly, this isn't always the case.

In the latest wave of phone calls the Indian-based call center will usually identify as Nexus Money although they've also identified as Parramatta-based Aussie Financials and a few other non-existent brands (I spoke to Australian Financial Market - the owners of the AussieFinancials website my call-center friend claimed as his own - and while they do have their own offshore call center primarily dedicated to customer service, they do not engage in this type of selling). The tactics used to make a booking with a broker have not changed since we previously described them.

We made the point last week that it's time to stop feeding the 'Marketing Sharks'... and this is yet another reason why marketing in the finance space needs better industry oversight and better broker education.

While we're not entirely confident the infractions will be fully investigated, we've reported the conduct to ASIC, the Federal Police, AMCA, and other appropriate bodies in order to have the matter resolved. We've provided our recorded telephone calls and other evidence that clearly identifies the individual responsible for the misconduct.

These inexpensive and illegally obtained offshore leads are the blood-diamonds of the mortgage industry and the practice has to come to an end.