Growing curation of regulatory assault on third-party lead generation
Roll up of current actions and key commentary
Well, there is definitely a concerted effort to curtail third-party lead generation.
I’m still combing through the documents. However, a cursory glance confirms that the FCC, FTC, and CFPB carefully categorize every standard practice in third-party performance/digital marketing as prohibited.
Photo by Jaime Spaniol on Unsplash
Here are some key vectors that federal regulators are using in opinions and request for commentary that will make it very difficult for third-party lead generation companies to generate and sell leads to businesses.
Limit prior express consent to receive a call or text to one caller at a time. No more sending leads and transferring consent to multiple lead buyers.
No “pay-to-play” or preferential presentation of service providers based on payments to the marketing platform. No more sponsored or featured listings in click tables. No more preferential lead distribution based on lead pricing. No more optimizing monetization.
I’ll continue to monitor and report on these actions as they unfold, but until then, here is a stack of watching and reading material for your weekend.
Sources & Further Reading:
FCC Rules on Lead Generation "Consent Farms" to Capture Consent for Telemarketing Purposes
Public Knowledge Comment to the FCC’s “Targeting and Eliminating Unlawful Text Messages” [PDF]
Third-party lead generation at risk of shut-down: Protect yourself by building an internal lead generation strategy
The CFPB’s shock move could kill third-party lead generation as we know it. How does it affect you?
DID THE CFPB JUST KILL PING POST TRANSACTIONS?: Regulator Finds Sell of Transfer Leads to Highest Bidder May Violate RESPA
RESPA Advisory Opinion on Online Mortgage Comparison Shopping Tools [PDF]