Hate to bring some bad news, but this is bad news city.
Last week Public Knowledge filed a reply comment with the FCC asking the Commission to end lead generation as we know it. Completely.
Here is the ask:
[T]he Commission should issue a declaratory ruling to explicitly require that express consent to receive calls or texts must be made directly to one entity at a time in response to the 2020 petition of Assurance IQ, LLC.11 Even though Assurance requested that its petition be dismissed, the issues raised in the proceeding are critical for striking at one of the root causes of unwanted and illegal robocall proliferation: lead generators and data brokers. Lead generators and data brokers harvest consumer telephone numbers along with thin—if not outright fraudulent—consent agreements attached and pass on those numbers and supposed consents to telemarketers and scam callers.
That’s right, Public Knowledge is putting lead generators directly in the crosshairs, telling the FCC it must act to shut down third-party leads completely.
The reply goes on:
As described in the Public Interest Comments and Public Interest ex parte, an unwitting consumer might enter their phone number on a website purporting to give an insurance quote only to have that be interpreted as “explicit consent” to receive calls from literally thousands of “partners,” most of which have nothing to do with insurance. The opaque web of relationships between those collecting, distributing, and making calls further complicates efforts to trace a path of accountability for such actions.12 The Commission should take swift action to explicitly denounce these practices and clarify that they are illegal under existing law. Doing so would immediately have a significant impact on the commercial ecosystem that supports unwanted and illegal phone calls and text message.
This is a huge moment in time folks. If industry continues to rest on its laurels–literally no advocacy is taking place in front of the FCC right now by the lead gen industry–the FCC (particularly this FCC) is likely to act and in swift and damaging fashion.
There is a solution, of course. The Czar.
Well, R.E.A.C.H. 🙂
There is still time to submit to join the board (really it ends today but in light of this development I will extend a bit.) And those of you attending the Summit next week will have a chance to speak with a couple of R.E.A.C.H.’s executive members–so that will be fun.
Bottom line: it is an absolutely critical time for lead buyers to come together to set standards and best practices to present to the FCC for approval in connection with this latest set of comments. Once standards are created–needs to happen NOW folks–we can sit down with the Commissioners and their staff and present a PLAN to assure that RESPONSIBLE ENTERPRISES in the lead generation and direct to consumer game can live on.
Failing to do so will likely mean third party (and perhaps other) leads will be outlawed completely. Let those who have ears, hear. Trying to keep you folks in business. (And why am I the only one talking about this?)
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