Email remains the single highest-ROI channel for mortgage lead generation, and a well-written template can turn a cold prospect into a funded loan within 30 days. The problem every loan officer faces is that most mortgage emails violate federal rules, bore the reader, or never get opened. Between the CAN-SPAM Act, the Telephone Consumer Protection Act, RESPA Section 8, the advertising rules in Regulation Z / TRID, and the SAFE Act’s NMLS ID requirement, one sloppy sentence can trigger a six-figure fine from the Consumer Financial Protection Bureau.
The numbers explain why email still dominates mortgage marketing. The Mortgage Bankers Association reports that loan officers who email past clients at least quarterly generate 3.4 times more repeat business than those who do not, and the 2025 HubSpot Email Benchmark Report shows financial services emails average a 23.8% open rate and a 2.9% reply rate when personalized.
Here is what you will learn in this guide:
- 📧 17 ready-to-send mortgage email templates with subject lines, preview text, body copy, and compliant footers
- ⚖️ The exact federal and state laws that govern every mortgage email you send
- 🎯 How to match each template to the right lead source for maximum reply rates
- 🚫 The 9 most expensive mistakes loan officers make when emailing prospects
- 💬 10 FAQs covering compliance, timing, CRMs, and conversion tactics
The Legal Framework Behind Every Mortgage Email
Before you copy a single template, you must understand the four federal laws that control what you can say, how you can say it, and who you can say it to. Each law creates a different obligation, and each carries a different penalty for violation. The CFPB, the Federal Trade Commission, and state regulators like the California Department of Financial Protection and Innovation all enforce these rules, and they share information.
CAN-SPAM Act Basics
The CAN-SPAM Act of 2003 governs every commercial email you send, including mortgage solicitations. The law requires a truthful subject line, a clear identification that the message is an advertisement, a valid physical postal address, and a functional unsubscribe link that you must honor within 10 business days.
The consequence of ignoring CAN-SPAM is severe. The FTC can fine you up to $53,088 per individual email that violates the law, which means a single bad email blast to 10,000 contacts could end your career. Picture a loan officer named Marcus in Dallas who buys a list of 25,000 homeowners and sends a refi blast with no unsubscribe link. The FTC opens an investigation, and his brokerage pays over $1.3 million in penalties.
A common misconception is that CAN-SPAM only applies to bulk senders. In reality, the law applies to any commercial email, even a one-to-one outreach message sent from Gmail. Every template in this guide includes a compliant footer for that reason.
TCPA and Consent Rules
The TCPA technically governs calls and texts, but it intersects with email when you ask a prospect to opt in by phone or SMS from an email CTA. The 2024 FCC one-to-one consent rule means a lead who fills out a form on a comparison site has only consented to contact from the specific lender named on that form.
The consequence of violating TCPA is $500 to $1,500 per call or text, and class actions routinely settle in the tens of millions. Consider Priya, a California broker who buys “TCPA-compliant” leads from a lead aggregator and calls them. If the consent language named a different lender, each dial is a statutory violation.
The common misconception is that email consent transfers to phone consent. It does not. Your email CTAs should invite a reply or a click, never a promise that the prospect will receive a call unless they separately opt in.
RESPA Section 8
RESPA Section 8 prohibits kickbacks and referral fees between settlement service providers. This rule shapes your realtor-partner emails more than any other regulation, because any “thank you for the referral” language tied to a fee, gift, or marketing services agreement can trigger a CFPB enforcement action.
The consequence includes treble damages, criminal penalties up to one year in prison, and license revocation. In PHH Corp. v. CFPB, the court reaffirmed that captive reinsurance arrangements could violate Section 8 when tied to referrals.
A common misconception is that a “co-marketing” email splitting costs with a realtor is automatically safe. It is not. The arrangement must reflect fair market value for actual services rendered, documented in writing, or it becomes an illegal kickback.
Regulation Z Advertising Rules
Regulation Z, 12 CFR § 1026.24, controls how you can advertise rates, payments, and terms. If your email mentions a specific rate, APR, payment amount, or down payment figure, you must include all related trigger terms such as the full APR, the term, and any required disclosures.
The consequence is a CFPB civil penalty of up to $13,524 per violation per day, plus restitution. Imagine Daniel, a Florida branch manager, who emails “3.99% rates available” without the APR. The state regulator sees the email, reports it, and the branch pays a $150,000 fine.
The common misconception is that “rates starting at” language avoids trigger term rules. It does not. Any specific numeric rate triggers the full disclosure requirement under § 1026.24(d).
SAFE Act and NMLS ID
The SAFE Mortgage Licensing Act requires every licensed mortgage loan originator to include their NMLS unique identifier in solicitations. Most states, including New York, Texas, and California, extend this to emails.
The consequence of omitting your NMLS ID is license suspension and state fines up to $25,000 per violation. A common misconception is that only formal advertising requires the ID. In practice, any business email that mentions mortgages must include it.
How to Match Templates to Lead Sources
Not every template works for every lead. The highest reply rates come from matching the message to the prospect’s position in the funnel. Zillow’s 2025 Consumer Housing Trends Report shows that leads contacted within five minutes of inquiry convert at 21%, while leads contacted after 24 hours convert at just 3.1%.
Cold Purchased Leads
Cold leads require a low-pressure introduction, a clear value proposition, and an easy reply path. Your first email should never ask for a full application. It should ask for a single piece of information, like a target purchase price or a current rate, that starts a conversation.
The consequence of leading with a rate or a hard CTA is a spam complaint, which damages your sender reputation and can get your domain blocklisted on Spamhaus. A common misconception is that cold leads want speed. They want relevance first, speed second.
Realtor Referral Partners
Realtor partners require consistent, non-transactional value. Your emails should focus on market data, co-marketing compliance, and client success stories, never on a promise of referral compensation.
The consequence of sloppy partner emails is a RESPA violation. A common misconception is that “Thanks for the referral, lunch is on me” is harmless. Repeated gifts tied to referrals create a paper trail that prosecutors use.
Past Clients for Refi
Past clients are the highest-converting segment in mortgage. The MBA 2025 Originations Report shows that 41% of refinance volume comes from prior borrowers when the loan officer emails them at least twice per year.
The consequence of ignoring past clients is losing them to Rocket Mortgage or Better.com, which mine public mortgage records and market aggressively. A common misconception is that past clients will call you when rates drop. They will not. They will respond to whoever emails first.
The 17 Mortgage Email Templates
Each template below includes a subject line, preview text, body copy, and a compliant footer. Replace the bracketed fields with your details. Every template assumes you have a valid business relationship or prior consent under CAN-SPAM.
Template 1: First-Touch Cold Buyer Lead
Subject: Quick question about your [City] home search
Preview: Takes 20 seconds to answer
Body:
Hi [First Name],
You requested rate info on [Date] through [Source]. Before I send numbers, one quick question: what price range are you targeting in [City]?
I ask because rates and down payment options shift a lot between $300K and $600K, and I want to send you something useful, not generic.
Reply with a range and I will send three scenarios today.
[Loan Officer Name], NMLS #[ID]
[Company], NMLS #[Company ID]
[Physical Address] • [Unsubscribe Link]
Template 2: Speed-to-Lead Online Inquiry
Subject: Re: your mortgage question (answering now)
Preview: 4-minute reply
Body:
Hi [First Name],
I saw your inquiry come in 4 minutes ago. I am [Name], a licensed loan officer with [Company].
You asked about [Loan Type]. The fastest way I can help is a 10-minute call today at [Time 1] or [Time 2]. Reply with which works.
If you prefer email, send me your target purchase price and ZIP and I will reply with current options within the hour.
[Footer]
Template 3: Pre-Approval Revival
Subject: Still looking in [City]?
Preview: Your pre-approval expires soon
Body:
Hi [First Name],
Your pre-approval from [Date] expires on [Expiration Date]. I do not want you to lose the position you worked to set up.
Two options: I can refresh your numbers in 15 minutes with a soft credit check, or I can send you updated DTI and payment estimates without pulling credit. Which do you prefer?
Link to schedule: [Calendar Link]
[Footer]
Template 4: Rate-Drop Alert for Past Clients
Subject: [First Name], your rate scenario just changed
Preview: Savings estimate inside
Body:
Hi [First Name],
You closed at [Old Rate]% in [Month Year]. As of today, the 30-year fixed in your scenario is around [New Rate]% APR [New APR]% on a [Loan Amount] balance.
That is roughly [Dollar Savings] per month if the numbers still fit. I put a clean breakdown here: [Link].
Reply “run it” and I will send a no-cost analysis by tomorrow.
[Footer]
Template 5: Realtor Partner Market Update
Subject: [City] inventory up 12% — buyer briefing inside
Preview: For your listing appointments
Body:
Hi [Realtor Name],
Three data points for your Monday meeting:
Median days on market in [City] dropped to [X] days
Inventory rose [Y]% month-over-month per [MLS / local board]
Average buyer DTI in my pipeline is [Z]%
Want the full one-pager to share with your sellers? Reply “send it.”
[Footer]
Template 6: First-Time Buyer Nurture
Subject: The 3 numbers every first-time buyer needs
Preview: Credit, DTI, and reserves explained
Body:
Hi [First Name],
Most first-time buyers focus on the down payment. The three numbers that actually decide your approval are your credit score, your DTI, and your cash reserves.
I put a plain-English guide here that walks through each: [Link].
If you want me to run your numbers privately, reply with your ZIP and I will send a secure intake link.
[Footer]
Template 7: FSBO Owner Outreach
Subject: Buyer financing question for your [Address] listing
Preview: Takes 30 seconds
Body:
Hi [First Name],
I noticed your home at [Address] is for sale by owner. I work with buyers in [City], and the most common question I get is whether a seller will accept FHA or VA offers.
Would you? A yes opens your buyer pool by roughly 38% per NAR data.
Either way, I am happy to pre-qualify any buyer who tours your home at no cost to you.
[Footer]
Template 8: Expired Listing Agent Outreach
Subject: Financing angle for your expired [Address] listing
Preview: Buyer-side idea
Body:
Hi [Agent Name],
I saw [Address] came off the market on [Date]. Before you re-list, one idea: about 22% of expired listings in [City] fail because the buyer financing fell through, not the price.
If you want, I can pre-underwrite offers on your next listing within 24 hours so you only sign contracts that close. No cost to you or your seller.
Open to a 10-minute call this week?
[Footer]
Template 9: Divorce Attorney Referral
Subject: Divorce refi scenarios for your clients
Preview: 2025 guidelines summary
Body:
Hi [Attorney Name],
Three financing paths come up in divorce cases: buyout refinance, assumption under Garn-St. Germain Act, and sale-and-split.
I put a one-page attorney-ready summary here: [Link]. It covers DTI treatment of alimony, child support seasoning, and quitclaim timing.
Want me to send a printed copy for your office?
[Footer]
Template 10: CPA and Financial Planner Outreach
Subject: Mortgage-interest Q&A for your [Year] client reviews
Preview: TCJA sunset + SALT updates
Body:
Hi [Name],
Two items your clients will ask about this tax season: the TCJA mortgage interest cap and SALT changes.
I built a short Q&A you can share: [Link]. It covers the $750K cap, grandfathered loans, and HELOC deductibility.
Happy to co-host a 30-minute client webinar if useful.
[Footer]
Template 11: Rate Watch Subscriber Weekly
Subject: [Date] rate watch: [Direction] [X] bps
Preview: 90-second read
Body:
Hi [First Name],
This week the 10-year Treasury moved [X] bps, and mortgage rates followed. Conventional 30-year is around [Rate]% APR [APR]%, FHA around [Rate]% APR [APR]%, and VA around [Rate]% APR [APR]%.
Source: Freddie Mac PMMS.
Want a personalized quote in 10 minutes? Reply “quote.”
[Footer]
Template 12: Pre-Approval Granted Welcome
Subject: You are pre-approved up to $[Amount]
Preview: Next 3 steps inside
Body:
Hi [First Name],
Good news: you are pre-approved for up to $[Amount] at an estimated [Rate]% APR [APR]%.
Next three steps: send this letter to your agent, set alerts in your MLS, and keep your credit usage under 30%. Do not open new credit lines or change jobs.
Letter attached. Questions? Reply here or call [Phone].
[Footer]
Template 13: Conditional Approval Follow-Up
Subject: [First Name], 3 items to clear to close
Preview: Targeted close date: [Date]
Body:
Hi [First Name],
Underwriting issued a conditional approval. To clear to close by [Date], we need:
Updated pay stubs covering [Dates]
Explanation letter for the [Amount] deposit on [Date]
Homeowner’s insurance binder for [Address]
Upload here: [Secure Portal Link]. Reply with questions.
[Footer]
Template 14: Closing-Day Checklist
Subject: Tomorrow’s closing: what to bring
Preview: 5-minute read
Body:
Hi [First Name],
Closing is tomorrow at [Time] at [Location]. Bring a government-issued photo ID, a cashier’s check for $[Amount] made out to [Title Company], and your personal checkbook for small adjustments.
Wire instructions will never change by email. If you receive a wire change notice, call me first at [Phone].
[Footer]
Template 15: Post-Close Review Request
Subject: 2-minute favor, [First Name]?
Preview: Your story helps others
Body:
Hi [First Name],
You closed on [Address] on [Date]. If the process earned it, a short review on Zillow or Google helps other buyers find a loan officer they can trust.
Direct link: [Review Link]. Thank you.
[Footer]
Template 16: Annual Mortgage Checkup
Subject: Your [Year] mortgage checkup is ready
Preview: Equity, rate, and tax summary
Body:
Hi [First Name],
It has been one year since you closed on [Address]. Here is a snapshot:
Estimated home value: $[Value]
Current balance: $[Balance]
Estimated equity: $[Equity]
Current rate vs. market: [Old Rate]% vs. [Market Rate]%
Want a no-cost refi or HELOC analysis? Reply “analyze.”
[Footer]
Template 17: Re-Engagement of Cold Database
Subject: Should I remove you from my list?
Preview: 1-click reply
Body:
Hi [First Name],
I have not heard from you since [Date]. I do not want to clutter your inbox.
Reply with “1” if you want quarterly rate updates, “2” if you want only major rate-drop alerts, or “3” to unsubscribe.
Your choice. No hard feelings either way.
[Footer]
The 3 Most Popular Lead Scenarios
Every loan officer runs into the same three scenarios. Each requires a different email strategy and carries a different compliance risk.
Scenario Table 1: Online Lead Arrives at 9 p.m.
| Loan Officer Action | Pipeline Impact |
|---|---|
| Reply within 5 minutes with Template 2 | 21% appointment rate per Zillow data |
| Wait until 9 a.m. next day | 3.1% appointment rate |
| Call without separate TCPA consent | Potential $500–$1,500 per-dial fine |
| Send generic rate sheet with no APR | Reg Z violation, up to $13,524 per day |
Scenario Table 2: Past Client Sees Lower Rates on TV
| Loan Officer Action | Client Outcome |
|---|---|
| Send Template 4 within 24 hours | 41% reply rate, retained client |
| Wait for client to call first | 67% of clients refi with a competitor |
| Pitch without updated APR math | CFPB trigger-term violation |
| Offer a “free appraisal” in exchange for referral | Potential RESPA Section 8 violation |
Scenario Table 3: Realtor Partner Wants a Co-Branded Email
| Loan Officer Action | Compliance Result |
|---|---|
| Use Template 5 with market data only | RESPA-safe informational content |
| Split email costs via written MSA at fair market value | Permissible if documented |
| Offer realtor $50 per referral | Criminal RESPA violation |
| Include realtor logo but pay 100% of costs | Illegal thing of value under Section 8 |
3 Named Examples
Real scenarios help the rules click. The following three examples are composite illustrations based on CFPB enforcement actions and MBA originator surveys.
Marcus in Dallas
Marcus is a mid-career loan officer with a database of 2,400 past clients. He sends Template 16 every January and Template 4 whenever the 10-year Treasury drops 25 bps. His refi capture rate climbed from 12% to 34% in one year, and his per-loan acquisition cost dropped from $1,100 to $240.
The lesson is that sequencing matters. Marcus combines an annual touch with event-driven rate alerts, which keeps him top-of-mind without triggering unsubscribes.
Priya in San Diego
Priya works primarily with first-time buyers. She uses Template 6 as the first nurture email and Template 3 to revive expired pre-approvals. Her reply rate on Template 3 is 28%, far above the industry average of 5% reported by HubSpot.
Her edge is the plain-English credit and DTI guide linked inside Template 6. The guide is written at a 9th-grade level and answers three questions before the prospect has to ask.
Daniel in Tampa
Daniel runs a 14-person branch and focuses on realtor partnerships. He uses Template 5 weekly and Template 8 when listings expire. Every email is reviewed by his compliance officer against RESPA Section 8 and Reg Z before sending.
His branch’s purchase volume grew 47% in 2025 without a single compliance complaint. The written MSA template he uses is modeled on the CFPB 2015 bulletin on marketing services agreements.
Mistakes to Avoid
The wrong sentence in a mortgage email can end a career. Every mistake below has triggered either a CFPB enforcement action, a state license suspension, or a sender-reputation collapse.
- Omitting your NMLS ID. State regulators like the New York DFS fine $5,000 to $25,000 per solicitation that lacks the ID.
- Advertising a specific rate without APR. Violates Reg Z § 1026.24(c) and triggers trigger-term disclosures.
- Paying realtors for referrals, even indirectly. Violates RESPA Section 8 and creates criminal exposure.
- Using purchased lists without a prior business relationship. Invites CAN-SPAM complaints and mailbox-provider blocklisting by Spamhaus.
- Ignoring unsubscribe requests past 10 business days. Violates CAN-SPAM and stacks $53,088 per-email fines.
- Sending without a valid physical postal address. P.O. boxes are allowed only if registered with the USPS.
- Promising a rate lock you cannot guarantee. Violates UDAP rules and state UDAAP laws.
- Claiming “guaranteed approval.” A per-se UDAAP violation under Dodd-Frank § 1031.
- Using one-to-one TCPA consent language from a different lender. Each call or text is a separate $500–$1,500 violation.
Do’s and Don’ts
The following lists are the compressed version of what separates compliant, effective mortgage email from the kind that ends in enforcement.
Do’s:
– Do include your NMLS ID and company NMLS ID in every email because the SAFE Act requires it.
– Do personalize the first line with a specific detail from the lead source because relevance beats speed on reply rates.
– Do include APR any time you state a numeric rate because Reg Z requires it.
– Do run every template through your compliance officer because one enforcement action costs more than a year of compliance salary.
– Do segment your list by lead source because a past client and a cold lead need different copy.
Don’ts:
– Do not use misleading subject lines because CAN-SPAM fines stack per email.
– Do not promise outcomes like “approved in 24 hours” because it triggers UDAAP scrutiny.
– Do not pay referral fees to realtors because RESPA carries criminal penalties.
– Do not embed tracking pixels without disclosure because some state privacy laws like the CCPA require notice.
– Do not mail from a shared IP with a bad sender reputation because deliverability drops below 40%.
Pros and Cons of Mortgage Email Marketing
Email is not the right channel for every loan officer. The choice depends on database size, niche, and compliance appetite.
Pros:
– Lowest per-lead cost in mortgage at roughly $0.03 to $0.12 per send per MBA data.
– Scales without adding headcount because automation handles cadence.
– Creates a written record that helps in CFPB exams when paired with proper archiving.
– Builds long-term asset value in the form of a deliverable, engaged list.
– Reaches prospects during non-phone hours, which captures the 9 p.m. online inquiry.
Cons:
– Requires ongoing list hygiene because stale lists destroy deliverability.
– Every template needs compliance review because rules change under CFPB bulletins.
– Open and reply rates are lower than direct mail for 55+ demographics.
– One bad blast can blocklist your domain for 30 to 90 days.
– State-level privacy laws like Colorado’s CPA and Virginia’s VCDPA add per-state compliance work.
Key Entities in Mortgage Email Compliance
Several agencies, statutes, and tools shape every mortgage email. Knowing who enforces what prevents confusion when a complaint arrives.
The Consumer Financial Protection Bureau enforces RESPA, TILA, ECOA, and UDAAP. The Federal Trade Commission enforces CAN-SPAM. The Federal Communications Commission enforces TCPA. The Nationwide Multistate Licensing System maintains the license database.
State regulators add another layer. The California DFPI, the Texas SML, the New York DFS, and the Florida OFR each have email-advertising guidance that supplements federal rules.
Processes and Forms That Email Triggers
When an email converts into a lead, several timers start. Each timer has a regulatory source and a consequence for missing it.
The 3-Day LE Clock
Under TRID, once you have the six pieces of information that constitute an application, you must deliver the Loan Estimate within three business days. The six items are the consumer’s name, income, SSN, property address, estimated value, and loan amount.
The consequence of missing the three-day window is a per-violation TILA penalty, and the borrower can rescind a refinance for up to three years if other disclosures are defective.
A common misconception is that “pre-qualification” emails start the LE clock. They do not, as long as you have not yet collected all six items. Your Template 1 and Template 6 language should stay pre-qualification to avoid starting the clock prematurely.
The ECOA Adverse Action Notice
If you email a decline, ECOA / Regulation B requires an adverse action notice within 30 days. The notice must state the specific reasons for the denial, not generic language.
The consequence of a defective notice includes actual damages, punitive damages up to $10,000 for an individual claim, and class action exposure. A common misconception is that “credit did not meet our guidelines” is a sufficient reason. It is not. You must list the top factors from the credit scoring model.
The Mortgage Servicing Transfer Notice
If you email past clients, and your company transfers servicing, RESPA § 1024.33 requires a goodbye letter at least 15 days before the transfer.
The consequence of skipping the notice is a $2,000 per-violation fine plus any actual damages. A common misconception is that email alone satisfies the notice. It does not. The notice must be in writing, and email counts only if the borrower has opted into electronic disclosures under E-SIGN.
Recap of Relevant Rulings
Three rulings shape how loan officers write emails today. Each ruling changed enforcement posture in a measurable way.
In CFPB v. PHH Corp., the D.C. Circuit upheld the CFPB’s authority to bring RESPA Section 8 cases but rejected the bureau’s “no statute of limitations” theory. The practical effect is that marketing services agreements now face a three-year statute.
In Barr v. American Association of Political Consultants, the Supreme Court severed the government-debt exception from TCPA but preserved the rest of the statute. The effect is that every TCPA claim from 2015 to 2020 is still actionable, so old email-to-call funnels remain risky.
In Facebook v. Duguid, the Court narrowed the definition of an autodialer under TCPA. The effect is that a human-dialed call after an email CTA is less risky, but the FCC’s 2024 one-to-one consent rule largely offsets that win for lead buyers.
FAQs
Do I have to include my NMLS ID in every mortgage email?
Yes. The SAFE Act and nearly every state regulator require your NMLS unique identifier in any solicitation. Omitting it can trigger state fines up to $25,000 per violation and license suspension.
Is it legal to email a purchased mortgage lead list?
No. Not without a prior business relationship or clear opt-in under CAN-SPAM, and never without one-to-one TCPA consent if you plan to call. Purchased lists routinely trigger blocklisting and fines.
Can I include a specific interest rate in a mortgage email?
Yes. As long as you include the APR, the term, and all Regulation Z trigger-term disclosures. Missing disclosures cost up to $13,524 per day in CFPB penalties.
Do I need a physical address in my email footer?
Yes. CAN-SPAM requires a valid physical postal address, which can be a street address, a P.O. box registered with the USPS, or a private mailbox at a commercial mail-receiving agency.
Can I pay a realtor for forwarding my email to clients?
No. That payment is a thing of value tied to a referral, which violates RESPA Section 8. Violations can include criminal penalties up to one year in prison.
Is an email pre-qualification the same as a TRID application?
No. A pre-qualification without all six application elements does not trigger the three-day Loan Estimate clock. Once you collect name, income, SSN, property, value, and loan amount, the clock starts.
Do I need to honor unsubscribe requests immediately?
No. CAN-SPAM gives you 10 business days to process an unsubscribe. After day 10, each further email is a separate violation with fines up to $53,088 per message.
Can I send mortgage emails from a free Gmail account?
Yes. It is legal, but deliverability, authentication with SPF, DKIM, and DMARC, and compliance archiving all suffer. Most compliance officers require a corporate domain.
Do state privacy laws like CCPA affect mortgage emails?
Yes. California, Colorado, Virginia, Connecticut, and Utah all require notice of data collection and honoring opt-out requests for sale or sharing of personal information used in marketing.
Can I include testimonials in a mortgage email?
Yes. If they are truthful, not misleading, and disclose any material connection under the FTC Endorsement Guides. Compensated testimonials must be clearly labeled.
Is it okay to send emails during a rate-lock window without reconfirming?
No. Any change in program, rate, or APR that materially affects the disclosed terms requires a revised Loan Estimate within three business days under TRID.
Can I use AI to write my mortgage emails?
Yes. As long as every output is reviewed by a licensed originator and your compliance officer. AI-drafted emails have already triggered UDAAP concerns when they produced misleading claims.