As both a Board member of the exciting new LeadsCouncil (www.leadscouncil.com) and a compliance-minded member of the Digital Performance Marketing industry for the past 20 years, I flew to Washington D.C. this week with my Chief Compliance Officer to attend an FTC workshop on lead generation. We had received notice that the FTC was going to hold a panel discussion on lead generation in the lending and education verticals, and we wanted to attend. LeadsCouncil Board members Greg Gragg and Michael Ferree were both panelists at the event, and the council was also indirectly represented by VP & Head of Compliance, John Henson from Tree.
These types of panels and acceptance of written comment are usually a precursor to enhanced enforcement efforts or proposing additional regulation. Discussions around these events focused on tools and processes that consumers and businesses could use to determine where and how their information was being used as well as the current disclosures, and whether they are enough to protect the consumer. The following is a summary of the topics and issues discussed and topics to think about to improve your business practices:
What is important to the consumer?
- Receiving reliable, accurate information on the products and services they requested.
- Competitively-priced options to ensure consumers get the best price for the best service.
- Expectation that their data and information will be protected.
- To control the flow of communication during the decision-making process.
- Personalized search options to only receive options that meet their criteria.
What is important to the advertiser?
- Quality leads and accurate information
- High interest level to purchase (intent)
- Clear and transparent marketing processes by lead generators for compliance.
What is important to regulators?
- Responsible online collection, use, and protection of consumer data.
- Efficacy of existing laws and regulations to deter and/or enable prosecution of bad actors or practices.
- Strong industry compliance and self-regulatory framework with “teeth.”
- Understanding the consumer complaint landscape and whether or not the specifics and volume of the complaints necessitate agency action.
- Pressure from Capitol Hill or other consumer protection agencies.
What is important to the marketer (lead generator)?
- Exclusivity and ownership of the information or lead if they generated it.
- Protecting lead generation channels
- Getting a fair price
- Protecting data
- Federal and state compliance
A video of the event is in three parts and starts here: