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One To One Consent Required In


From The Beginning - What Is Happening With Lead Generation And The FCC?

The FCC's recent actions to close the "lead generation loophole" significantly impact the lead generation industry, emphasizing the importance of dynamic consent. They are trying to help consumers combat robocalls and spam texts mainly through stricter consent requirements. For everyone, it means ensuring that one-to-one consent is obtained for each seller,  which is a significant shift from previous practices. You can learn more about the specifics of the ruling here

Download Our FCC One-To-One Consent Whitepaper!

What Is Dynamic Consent?

Dynamic consent is the way forward, considering how you need one-to-one consent when contacting leads. What is dynamic consent? "Dynamic consent is the ability to return potential service providers to the consumer, allowing them to select who gets their information." Dynamic consent even allows you to keep using ping post in your strategy, read more about that here

Dynamic Consent Infographic - Final

What Solutions Do You Have For Complying With This Ruling?

boberdoo has 4 different solutions that you can customize to your lead flow:

Click-through traffic - easiest
Dynamic consent widget - easy
Form Builder with dynamic consent - more customized
Ping Post with APIs - most custom option

Read more about what each do here

What Does This Mean For The Lead Generation Industry?

The FCC's new regulations significantly affect the lead generation industry, emphasizing strict compliance with one-to-one consent for calls and texts. This change requires leads to proactively select which sellers they wish to be contacted by, eliminating automatic matching and the use of broad lists. To assist you in aligning with these guidelines, here's a guide of 8 steps for transitioning your company to a post-FCC industry. Dynamic consent aligns with these regulations by each lead explicitly agreeing to be contacted by specific companies, thus maintaining compliance while also enhancing lead quality. This approach is crucial for businesses to adapt to the evolving legal landscape and consumer expectations in lead generation. See here for a more detailed breakdown of the FCC ruling. 

Why Is The FCC Pushing To "Close The Lead Generation Loophole"?

This may seem like a harsh ruling for the industry, and it is, but bad actors in the industry are the reason this is happening. No one likes receiving over 300 calls in two days; yes, that happened to us or getting spam texts. Unfortunately, the companies following the rules have to deal with this, but ultimately, it helps with the overall quality of leads in the long run and helps give trust back to the consumers when forms are filled out, and phone calls are made. 


We hosted a webinar discussing the common questions we've gotten about the FCC, Dynamic Consent, One to One Consent and everything else around those subjects, you can check out the recording here. Also if you would like to join our webinars in the future, you can sign up here. Without further ado, here are our most frequently asked questions. 

How are calls affected for one-to-one consent?

In the context of inbound calls, when dialing a number, they are not subject to the one-to-one consent requirement for submitting data leads. This is similar to click opportunities, where the user initiates an action and goes to a website to monetize that click. However, you will need to get that explicit consent for outbound calls. 

Is SMS dead in this world for the lead generator?

When it comes to sending outbound texts to consumers in bulk, dynamic consent is necessary. Specifically, one-to-one consent is required for this type of communication. The opt-in process, which involves TCPA language, becomes crucial in obtaining consent. It's recommended to have appropriate language for TCPA compliance on the page, and we suggest consulting with in-house legal teams or attorneys to ensure compliance.

How can 3rd party software like Journaya be utilized for Dynamic Consent? 

To integrate third-party software such as Jornaya or TrustedForm, you can leverage the boberdoo Form Builder. The Form Builder supports APIs for various functionalities to incorporate third-party scripts. As a lead generator, you can add the TrustedForm or the Jornaya script to your landing pages where leads are generated. These scripts capture information upon lead submission, generating a unique ID that is then included with the other lead fields. This serves a dual purpose. Firstly, the captured information can be used to either reject or proceed with the lead processing, for instance, relating to the originating domain or age for example. Secondly, the account owner can claim the certificate, providing evidence or proof that the consent was captured.

If we ping a network buyer, and the network returns an end buyer name (which is different from the name of the network), will the ping reply to our website be able to show the end buyer's name (and not the network's name)?

You need to display the end seller's name. For example, if the network returns " Company A " as their end buyer in a non-exclusive scenario, it will be displayed accordingly. The documentation or logging in the lead system will show that network one was the buyer who purchased the lead on behalf of or sold it to "Company A." boberdoo partners will have new labels related to one-to-one consent and seller resellers, aiding in organization and labeling for transactions.

Can checkboxes be pre-populated for consent? 

Regarding checkboxes, they cannot be pre-populated; the consumer must explicitly choose them. This is a requirement for explicit consent, and consumers must take action. It is encouraged to test the effect of displaying multiple companies, as it may vary across different verticals. Some verticals may see improved revenue with various displays, while others prefer a single display. Each company's marketing approach will differ, so starting A/B tests early is advisable.

As a lead buyer (now called Seller by FCC), how can a company ensure leads are explicitly consented to by the consumer? 

Firstly, anticipate changes in relationships between lead buyers and sellers, where having a direct relationship with any reseller or lead generator becomes crucial. From a technical perspective, services like Jornaya and Trusted Form may be necessary to verify that your company name is appropriately displayed for dynamic consent. In the context of boberdoo, clients have been using external services for similar purposes. During the ping or post-process, calls to third parties can be made to verify information, allowing for the continuation of lead processing or bidding only when your company information is displayed.

What are the rules for what needs to be displayed for one-to-one consent?

In certain instances, there's a distinction between displaying just the company name (e.g., Allstate) versus a company franchise. In the latter case, the individual franchise must be displayed as the company contacting the consumer. Ultimately, sellers must consult with their legal representation within this ecosystem to determine what information each company should return.

How do you handle responses from other resellers?

The dynamic consent processing logic moves upfront, where distribution logic occurs before consumers are presented with leads. Behind the scenes, there are three main processing logics:

What happens if I have five companies I could potentially display on this form?

The system decides who gets selected based on sorting logic if you want to display up to five sellers but have more than five potential sellers. Sorting can be based on factors such as best price, best-expected revenue per display, or weighted logic for priority distribution. Learn more about each here. 

What company info do we need to display?

The sorting logic, especially for best price, becomes crucial when considering what company information to display. Duplicates and de-duping are essential considerations to ensure a good user experience. There are ongoing discussions about using unique fields like Duns number to avoid issues with similar names, such as "Allstate" versus "Allstate Inc."

Do they have to check the box, or can it automatically be checked upon the page load if we sell the leads exclusively? 

If you exclusively sell leads, there's an option for automatic consent without a checkbox. The boberdoo Form Builder provides a feature called "Consent Exclusive Match." This option, either returned in the API response or integrated into the logic of the Form Builder, allows for a single select consent flow. In this scenario, individual companies are not explicitly listed; instead, magic strings can be used to dynamically display the company name, website, and phone number in the TCPA terms. This streamlines the consent process, eliminating the need for a separate checkbox for each company and ensuring a more efficient user experience. The Form Builder dynamically adjusts based on whether it's an exclusive or non-exclusive match, providing flexibility for lead generators in both scenarios.

Would we have to return the net dollars for each lead in order for boberdoo to know the expected earnings?

No, returning net dollars for each lead is not required for boberdoo to calculate expected earnings. All revenue from direct sellers or resellers is tracked within the boberdoo system. The necessary data for calculating expected earnings, including revenue from different systems, is available for running calculations. When logging a reseller transaction, the system captures the specified sub-seller to whom the lead was routed, enabling accurate revenue tracking through the entire transaction process.

What about post rejects? If a consumer selects a company and post rejects the lead, how do you chase down the consumer to try again?

Post rejects can be addressed through thank-you page management and a feature called the dynamic consent widget. When a lead is post-rejected, there are two potential reasons: failure in lead scoring or a rejection by the selected partner. For the former, options in the boberdoo Form Builder allow for excluding the chosen partner and displaying the remaining ones or generating a new list of partners. So when the consumer selects that company, within milliseconds, it will be post rejected, so the lead is then taken to the thank you page where there is a message about how they were not able to be connected to that Seller (buyer) and list the remaining sellers for them to consent to instead. 

The dynamic consent widget is a solution for those hesitant to change their forms. It's a widget placed on the thank-you page, utilizing JavaScript to display TCPA text and dynamically match partners to the lead. This approach offers flexibility in monetization strategies. For instance, if the only buyer post-rejects the lead, you can redirect it to a click-off or trade to monetize it. The widget captures advantages by already having the lead information and provides opportunities for additional marketing, incentivizing consumers to select multiple sellers.

Additionally, the entire lead is already captured, and if the consumer doesn't take action or exits the browser, the system provides options. The one-to-one options enable automatic reprocessing of the lead at the end of the expiration time, specifically targeting partners that do not require one-to-one consent. Learn more about partners that do not require consent here. This allows for continued lead monetization even if the consumer still needs to select a specific company.

If a lead returns to the form, will they have to resubmit their PII?

With boberdoo, no, they won't have to resubmit their Personally Identifiable Information (PII). The information is stored in the boberdoo lead system and is associated with the lead. Utilizing the JavaScript widget mentioned earlier, returning leads to the form won't require users to resubmit their information.

Can we offer the lead more than what they are filling the form out for?

The ability to offer the lead more than what they initially filled the form for depends on the logical relevance of the seller list. The list of sellers needs to be topically and logically related. For instance, if the landing page concerns roofing, the seller list should specifically relate to roofers. While the thank-you page is not the ideal place for diverse offers, there are alternative spaces like banner ads or click-throughs where additional advertising can occur. However, from a marketer's standpoint, the primary focus should be encouraging users to select multiple companies, as it presents the best opportunity for monetization.

If the lead bounces off the page on the thank you page but already submitted their info, can we reach out to them directly to try to save the lead?

If the lead bounces off the thank-you page but has already submitted their Personal Identifiable Information (PII), the ability to reach out to them directly depends on the language and consent provided on the initial form. Typically, the TCPA text on the first form may include a statement that the company and its affiliates or marketing partners may contact the individual relating to email. Reaching out to save the lead could be permissible if such language is present. However, it's crucial to err on the side of caution and adhere to the consent and language provided on the initial form, especially for calls or texts. 

If the Seller owns the domain they are on, does there need to be a check box at all? For Insurance: Can the Seller listed be a Carrier, and can the lead be sold to any Agent within the carrier? Or does it need to list an Agent's Name / Number?

If the Seller owns the domain they are on, there may not necessarily need to be a checkbox. However, compliance with TCPA regulations still requires proper consent language, potentially integrated into the text rather than a separate checkbox.

Regarding insurance leads, it's not explicitly specified whether the Seller listed can be a carrier, and the lead can be sold to any agent within the carrier. While the regulations may not expressly outline the details, including the company name and potentially the specific agent within the carrier is advisable to ensure clarity and compliance. For instance, listing "Allstate" or "Allstate Holdings" may suffice. However, in franchises like "Keller Williams Real Estate," it might be necessary to list the individual franchise for accurate identification.

Dynamic consent is forcing consumers to check extra boxes. How can conversion rates be preserved?

The effectiveness of what you can do varies significantly across different industries. However, having additional options does present an opportunity to enhance revenue. By optimizing lead forms to highlight the advantages of choosing multiple companies or sellers, businesses can increase the value they derive from each lead. When consumers are presented with options that closely match their needs, they're more likely to select multiple partners, increasing the average revenue per lead. This scenario mainly benefits lead generators who can effectively communicate these benefits.

The importance of testing cannot be overstated in this context. Some clients have reported poor results, experiencing significant drop-offs when consumers are faced with these additional choices. However, other clients have found success, applying the 80-20 rule where a majority select the first option, but a significant minority opts for multiple partners, leading to increased matching and potentially higher conversion rates.

We are introducing a new form builder with our upcoming release to address these challenges, allowing for easy integration of dynamic consent in Google Ads campaigns. This tool enables A/B testing without requiring extensive development resources, offering insights into how such changes affect consumer behavior and conversion rates.

For instances where the results are less than favorable, we suggest incorporating a dynamic consent widget on the thank you page. This approach minimizes disruption to the existing lead flow by maintaining a single-page form. It introduces the option of selecting matching partners post-conversion. This strategy provides flexibility in managing leads, especially for those who may have yet to choose additional options initially.

There's a lot of talk about "cutting out the middleman." What does that mean if you're the middleman in a lead transaction?

The essence of this challenge lies in the inevitable drive toward efficiency within any marketplace, which often leads to a reevaluation of intermediary functions. For resellers, the path forward involves strategically emphasizing adding value to the transaction process. This can be achieved by understanding lead origins and the intricate relationships that define the lead generation ecosystem.

Historically, lead sources have engaged with many sub-identities or publishers. While resellers have played a key role in optimizing lead flow, there's been a hesitancy to communicate optimizations back to the lead generators. However, as market dynamics evolve, the importance of such communication is becoming increasingly apparent. By managing the nuances of account management, refunds, and day-to-day operations, resellers offer substantial benefits to lead buyers, particularly the smaller ones who might otherwise be overwhelmed by the complexities of direct dealings.

The value proposition of a reseller extends beyond mere transaction facilitation; it encompasses the management of relationships with lead generators, thereby acting as a bridge between the generation and the consumption of leads. While currently vital, this role faces the risk of becoming redundant over time as direct partnerships between lead generators and buyers become more common. The challenge for resellers is continuously evolving to offer services that justify their position in the lead transaction process.

What about the lead generators or resellers concerned with "poaching" of lead buyer information?

It's clear from recent conversations that distinguishing between different types of vendors—those genuinely contributing valuable leads versus those potentially exploiting the system for competitive intelligence—is a challenge. It is essential to root these vendors out, as outwardly similar engagement patterns (such as a high volume of low-conversion pings) can mask these harmful intentions.

To tackle this, we're developing tools like webhooks and leveraging our data science team to create alerts to identify unusual patterns based on historical data. These tools aim to provide real-time insights into any aberrations in buying rates that could indicate problematic behavior.

A practical solution involves using "seeded" contacts through our sister company, Assumed. This approach allows for monitoring how lead buyers are engaged by our partners, offering a safeguard against the unauthorized use of lead buyer information. We can track and reject suspicious leads by integrating these seeded contacts into your system as if they were genuine lead buyers, complete with specific filters. This method alerts you of potential poaching attempts by returning these seeded contacts in vendor responses. It provides concrete evidence of such activities through monitoring communications directed at these contacts.

This strategy serves a dual purpose: it helps identify sources attempting to poach your buyers. It reinforces the importance of working with reputable, trustworthy partners. Implementing such measures can significantly enhance the integrity of lead transactions, ensuring that your relationships with lead generators and buyers remain secure and productive.

Do you see DUNS number being the predominant ID being used to determine seller uniqueness? 

DUNS numbers, or Data Universal Numbering System numbers, serve as a unique identifier for businesses and play a role in verifying the identity and existence of a company. This becomes particularly relevant when dealing with resellers or sellers who are expected to provide evidence of one-to-one consent in their responses for an effective client sorting process.

In a scenario where a client is managing responses from various sellers, a unique identifier like the DUNS number may be needed to prevent redundancy and enhance the user experience. Displaying the same seller multiple times to a consumer is confusing. It can cause the lead to be sold multiple times to the same company. The DUNS number can help uniquely identify each seller, thereby avoiding repetition.

Integrating DUNS numbers into sorting logic includes calculating the expected revenue per display. This involves sophisticated tracking and analysis, including logging the frequency of a seller's appearance in responses, selection rates, and lead sales performance. Whether these interactions occur directly or through a reseller, the underlying goal is to ensure that each seller is uniquely identifiable and their performance accurately assessed.

The adoption of DUNS numbers for this purpose has been considered, with various stakeholders, including those involved in discussions about its implementation, exploring its viability. However, the effectiveness of using DUNS numbers hinges on the sellers' ability to provide them. This raises a question for businesses: Is it feasible for all parties involved in the lead transaction process to obtain and use DUNS numbers, given their scope and the requirements of their operations?

Ultimately, the decision to use DUNS numbers as the predominant identifier for seller uniqueness involves assessing their applicability to the business models of all stakeholders involved and determining whether they align with the operational and strategic objectives of managing seller identities efficiently.

What are good backup options for DUNS numbers?

A good solution must rely on the seller's name as an alternative identifier, complemented by intelligent checks to enhance reliability.

Using names raises concerns regarding standardization and consistency across the industry. By their nature, names may offer a different level of uniqueness or reliability than DUNS numbers or other unique identifiers. The potential for duplication or variation in names poses a significant challenge, necessitating a careful approach to managing and utilizing names within the system.

The discussion extends an invitation for feedback on the viability of using names as backup identifiers. It acknowledges the complexities and the need for a more reliable and standardized identification method. The goal is to find a balance between accessibility and accuracy, ensuring that the backup option complements the primary identifier without compromising the integrity of the identification process.

If 3 sellers are shown to the consumer but we match to just 1, does that satisfy 1:1 consent rules?

The core issue revolves around the potential underutilization of consumer interest. Suppose a consumer expresses a preference for multiple sellers. In that case, an opportunity exists to capitalize on this by facilitating transactions with each selected seller, thereby maximizing revenue. This approach aligns with the principle of leveraging consumer intent. It introduces a dynamic aspect to lead distribution, shifting the focus towards optimizing revenue opportunities through strategic seller selection.

Furthermore, this scenario prompts a reevaluation of existing lead distribution mechanisms, especially in cases of post-rejection by buyers. The efficiency of allocating space to sellers with a high rejection rate is scrutinized, as it could potentially limit revenue generation. The argument leans towards prioritizing sellers demonstrating a higher acceptance rate for leads, even if their bid might be lower, as this could result in a more consistent revenue stream.

The challenge lies in processing logic that respects the one-to-one consent framework and optimizes revenue by intelligently managing lead allocations. This requires a delicate balance between adhering to consent rules and maximizing the economic potential of each lead, urging lead generators and sellers to revisit and refine their operational strategies in light of these considerations.

Is best revenue scenario for ping post dead?

With one-to-one consent, the focus shifts towards representing specific buyers (or partners) in the bidding process, where bids are tailored for individual companies, and the ultimate choice of displaying information and securing consent rests with both the lead generator and the consumer.

This shift signifies a departure from generalized bidding to a more targeted strategy, emphasizing obtaining explicit consent for each potential transaction. It introduces complexity in managing bids and consent, necessitating adjustments in how bids are placed and processed.

The best revenue scenario remains viable and effective in contexts where one-to-one consent is not a prerequisite. This includes situations where complete lead information is collected before presenting sellers to the consumer, allowing for seamless execution of the best revenue strategy without the constraints imposed by one-to-one consent requirements.

Thus, while one-to-one consent introduces new considerations and challenges to the ping post model, it only renders the best revenue scenario obsolete. Instead, it prompts a strategic reevaluation and adaptation to for compliance with consent rules while striving for optimal revenue outcomes. This adaptation may involve leveraging dynamic bidding in environments free from one-to-one consent constraints or refining the approach to consent management where such requirements are enforced.

Is there a way to escape rebuilding all of the live forms?

The short answer is yes, there is a workaround that doesn't necessitate rebuilding all live forms from scratch, but this solution comes with its considerations.

One practical approach involves leveraging existing form structures while integrating new consent mechanisms on the confirmation or "thank you" page. This method allows for the dynamic presentation of matching partners based on the ping ID, aligning with the emerging standards of dynamic consent without altering the initial form. This setup keeps the front-end user experience unchanged. It does introduce a decision point at the end of the submission process.

This solution prompts further questions regarding managing leads still needing to select a company. If a consumer fails to make a selection, the lead remains in a consent-pending status, creating a potential bottleneck. The strategies to address this include remarketing to encourage completion of the consent process or implementing a system timer to automatically redirect leads to buyers who don't require one-to-one consent after a certain period.

Yet, this approach may inadvertently limit revenue potential since it restricts transactions to buyers not requiring direct consent. Moreover, there's the inherent risk of accumulating leads that, despite the resources invested in their acquisition, remain in a limbo state, unable to generate revenue due to the absence of explicit consent.

Given these complexities, it's advisable to consider A/B testing to explore the implications of adjusting the consent process. This could involve testing the efficacy of obtaining consent earlier in the lead generation process versus the proposed model of post-submission consent. Ultimately, finding a balance that maximizes lead conversion while adhering to consent regulations is key, necessitating a careful evaluation of the existing lead generation workflow and the potential impact of these adjustments on overall efficiency and revenue.

What solutions address the consumers who are just going to take the companies displayed and google them? Can a solution prevent giving the buyer free advertising?

The concern is valid: when consumers are presented with company names, they might bypass the lead generation system by directly searching for these companies on Google. Integrating multiple monetization opportunities within the response is the solution to mitigate this and ensure the lead generation effort remains monetizable.

One effective solution is the utilization of trackable communication methods. For instance, providing a trackable phone number through platforms like boberdoo allows the lead generator to direct consumer interactions (calls or texts) effectively. This method not only simplifies the process for consumers, potentially increasing engagement rates but also makes each interaction monetizable, regardless of whether it results in direct lead conversion.

Additionally, leveraging web-based interactions offers another layer of monetization. By including links to the company's website or a specific landing page within the response and making the act of clicking these links a billable event, lead generators can capture value from the initial research phase of the consumer journey. This approach encourages the consumer to use the provided links for research, which can be more convenient than conducting a separate Google search and allows the lead generator to benefit financially from these actions.

Implementing these strategies allows for the monetization of both direct interactions and preliminary research activities by consumers, effectively turning potential free advertising scenarios into revenue-generating opportunities. This aligns with the goal of maximizing the value of each lead and enhances the overall efficiency of the lead generation process.

What if there are no matches on the "ping"? Are the days of reprocessing the lead over?

When a lead cannot be matched with one-to-one consent partners in real-time, the question arises: what next steps can be taken to comply with consent requirements and ensure the lead is not wasted?

The reprocessing of leads, especially in the context of non-one-to-one consent partners, requires a nuanced approach. Initially, when a lead is submitted and fails to match specified sellers, or if a buyer rejects the lead post-submission, the lead generator is at a crossroads. One strategy involves redirecting the consumer to a confirmation page equipped with a widget to display a new set of potential partners, inviting the consumer to grant consent once again.

On the other hand, the introduction of dynamic consent options in the boberdoo Form Builder represents a significant evolution in handling unmatched leads. With the upcoming release of new form builder capabilities, lead generators will have the flexibility to define specific actions for leads that find no matches during the ping process. This includes the possibility of directing these unmatched leads towards "click only" buyers, effectively creating an opportunity to monetize leads that would otherwise remain unprocessed.

The system will offer settings to manage exclusive versus non-exclusive matches, enabling lead generators to tailor the consumer's experience based on the type of consent and match sought. This could involve embedding the information of an exclusive match within the TCPA (Telephone Consumer Protection Act) text or presenting multiple partners to the consumer for selection.

By leveraging these new tools and options, lead generators can take on the challenges of unmatched pings with greater flexibility and effectiveness, ensuring that the opportunities for reprocessing leads remain effective and compliant with consent frameworks.

Will we still be able to send partners emails as lead delivery?

Traditional lead delivery methods, such as plain text or HTML emails without encryption or password protection, no longer meet the stringent requirements set forth by these regulations for secure data transmission.

There are still viable options for email-based lead delivery that comply with these security mandates. One such method is delivering leads in the form of password-protected PDFs. This approach ensures that the lead information remains encrypted and only accessible to authorized recipients who have the password.

Integrating with a CRM (Customer Relationship Management) system is highly recommended for a more streamlined and secure process. A CRM can automate the ingestion of leads securely, providing a compliant solution and enhancing the efficiency of lead management practices. This necessitates that partners adopt suitable CRM systems capable of secure lead ingestion or implement password-protected document delivery to maintain compliance with data protection regulations.

What are the negative effects of 1:1 consent on small businesses? 

The requirement for one-to-one consent can complicate the lead generation process, potentially imposing additional operational and technical burdens on small businesses. These entities may need to invest in more sophisticated systems or processes to manage leads compliantly and effectively. Moreover, the emphasis on secure lead delivery methods is necessary for small businesses to adapt their practices to meet higher data protection and privacy standards.

In response to these challenges, providing enhanced value propositions through HTML offers, including logos, taglines, and discounts, becomes a strategic consideration. This approach aims to improve the attractiveness of small businesses to consumers within the consent-based framework. It highlights that small companies must enrich their offerings and communications to stand out in a competitive marketplace, where securing consumer consent and selection is the only option.

The upcoming changes to lead generation and management, with one-to-one consent and security requirements, prompt a reevaluation of the relationship dynamics between buyers, sellers, and resellers. For small businesses, adapting to these changes involves compliance and leveraging creative and strategic measures to enhance their visibility and appeal to consumers in a consent-driven environment to beat out the more prominent named companies.

How do you think one-to-one consent affects call aggregators who buy and sell consumer calls?

A significant portion of calls handled by aggregators originates from outbound efforts by call centers. These outbound calls are designed to initiate consumer engagement, which, when successful, results in an inbound call that can then be routed or sold through the aggregator's network.

Understanding the source and nature of these calls is important to pay attention to, especially those coordinating with multiple call centers. It's not just about routing calls but also the quality and compliance of these interactions. This requires a deep dive into the origins of the calls and a comprehensive vetting process for any new vendors or call centers entering the system.

The emphasis here is on transparency and accountability, as aggregators must prove that the consumer experience through these call flows adheres to regulatory standards and ethical practices. Establishing a vetting process enables aggregators to document and understand the consumer journey to check that the calls they buy and sell are generated in a manner that respects consumer rights and preferences. This approach safeguards the aggregator's operations from potential compliance issues. It will also enhance the quality and reliability of the service they offer buyers and sellers within the call aggregation ecosystem.

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