The Federal Communications Commission (FCC) has passed a new rule that will significantly alter the ability to leverage purchased leads for marketing and sales efforts.  

New rules 

  • One-to-one consent: Organizations who purchase leads have to get explicit, individual consent from each consumer before contacting them. This eliminates the ability to leverage leads from mass marketing campaigns based on generic consent forms 
  • “Logically and topically related: “Consent only applies to services aligned with the interest a consumer originally expressed. For example, someone who signs up for mortgage quotes can’t be contacted about car loans, insurance, credit cards, etc. 
  • Crackdown on lead sharing: Selling consumer information to multiple sellers will be prohibited 


This rule drastically impacts the ability to purchase and sell leads. The TCPA’s prior stance on express written consent did not explicitly address the use of lead generation. This rule puts that same burden on the lead buyers to gain such consent on a 1:1 basis, and solely for “logically and topically related” services the consumer expressed an interest in receiving. If an organization purchases leads, they will be prevented from being able to contact anyone without their specific, documented consent to the specific company contacting them. 


  • December 13, 2023: FCC voted to pass this rule, giving businesses six months to comply 
  • The rule will go into effect January 27, 2025.

What does this mean for organizations who purchase leads to sell their products and services to consumers? 

Businesses must make plans to change their marketing and sales strategy, focusing on securing individual consent for each contact, and investing in technology that can help them manage documenting consent data and ensuring compliance.  All businesses must be prepared to adapt their strategy to comply with the new rules. 

How Gryphon can help  

Gryphon’s real-time compliance solution provides a platform to automate the necessary internal procedures to operationally manage all compliance requirements, especially as it pertains to the capture, storing, and real-time monitoring of consumer express written consent.   

In addition, Gryphon’s automated call-blocking functionality will continue to play an important role in mitigating the risk of human error in making outbound calls to prohibited consumer telephone numbers. Due to the consistently changing landscape of DNC/TCPA guidelines, businesses must look to leverage technology to ensure each conversation with a new lead is maximized during outbound sales efforts and campaigns.  

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