This article will cover:
- Whats Is The FCC's 1-To-1 Consent Requirement?
- What Is The "Find Eligible Buyers" Feature In CAKE?
- How Is Buyer Eligibility Determined?
- How Do I Enable Find Eligible Buyers On My Offer?
- How Do I Make The Find Eligible Buyers Request?
- How Do I Skip Required Or Validated Fields On The Find Eligible Buyers Request?
- How Do I Skip Filters On The Find Eligible Buyers Request?
- How Do I Interpret The Find Eligible Buyers Response?
- How Does CAKE Order Eligible Buyers?
- How Do I Present Eligible Buyers To The Consumer?
- How Do I Support Lead Aggregators/Brokers With Multiple Sub-Bids?
- What is Consent Hierarchy?
- How Do I See Which Buyers Have Consent?
- FAQ
Whats Is The FCC's 1-To-1 Consent Requirement?
The Federal Communications Commission (FCC) has introduced new regulations in the US, effective January 27th, 2025, which will help combat illegal robocalls and robotexts. This ruling addresses common practices in the lead generation space where data is often resold and therefore contacted without clear, direct consumer approval first. The key requirement is one-to-one consent, meaning each consumer must provide explicit consent for their data to be shared with a specific buyer. Failure to comply with this regulation may lead to penalties, lawsuits, and repetitional damage.
What Is The "Find Eligible Buyers" Feature In CAKE?
CAKE's solution, referred to as Find Eligible Buyers, is designed to ensure compliance with the new FCC rulings while making it easy for our clients to integrate with their websites and current setups in CAKE. When enabled, CAKE dynamically identifies all the buyer(s) eligible to purchase the lead and presents a server-side response. The page owner is then responsible for storing this response, displaying key information to the consumer, then telling CAKE which buyers the consumer opted into so CAKE can appropriately route them.
Note:
Our solution is currently in BETA testing stage. Meaning, it is close to being finished but still being refined. Early Adopters are encouraged to provide feedback to help us identify any bugs or improvements needed before it's fully released.
How Is Buyer Eligibility Determined?
Eligibility is determined in 1 of 2 ways depending on the type of buyers you are working with:
- If working with a direct buyer, eligibility will be determined by evaluating the buyer's schedule, caps, credit, routing rules, filters, and other criteria configured directly in the CAKE UI.
- If working with a lead aggregator/broker (someone reselling the lead on their end) eligibility can further be determined by sending a ping to the buyer's system.
Note:
To successfully integrate a lead aggregator/broker, they must be able to support ping/post on their end and within their ping response, they must be able to include the name of their buyers and associated TCPA language per buyer.
How Do I Enable Find Eligible Buyers On My Offer?
To enable Find Eligible Buyers, follow these steps:
- Navigate to the Offer Card
- Click the Lead Gen tab
- Click the Routing sub tab
- Check the box for Enable Find Eligible Buyers
- Click Save
Note:
Ping First must also be enabled if you intend to dynamically fetch consent from your buyers and have it presented in the Find Eligible Buyers response. See section below titled "What Is Consent Hierarchy" for more details.
How Do I Make The Find Eligible Buyers Request?
The Find Eligible Buyers workflow uses a ping and post setup. Once the setting has been enabled on the offer, any successful Server Post or Session Post request to that offer will return the the Find Eligible Buyers response. This does not apply to Browser posts. The CAKE posting document, which can be located on the Home tab of the Offer card > Posting Doc button has been updated with detailed instructions.
Example Posting Document
https://cs1.cakemarketing.com/postinginstructionsFcc.aspx?o=1888&v=351&t=5
How Do I Skip Required Or Validated Fields On The Find Eligible Buyers Request?
In certain scenarios, clients may need to fetch eligible buyers before they have captured or validated all the fields required to sell the lead. For these reasons, CAKE offers the flexibility to skip selected fields during the Find Eligible Buyer request.
To skip a required or validated field, follow these steps:
- Open the Vertical card
- Navigate to the Fields tab
- Click the name of the field you want to exclude for the F.E.B request
- Click the Add button for any new validation or double click the row to adjust existing validation
- Check the box titled "Exclude From Eligible Buyers"
- Click Update to save
- Ensure the enabled indicator shows green
Note:
This setting can be overridden at the Offer Validation level as well. Simply navigate to the Offer card > Lead Gen tab > Validation sub tab.
How Do I Skip Filters On The Find Eligible Buyers Request?
Similar to required and validated fields, clients may need to find their eligible buyers before they have captured all the necessary fields that make the lead payable to affiliates or qualified for buyers. Since filters are created globally and can be applied as Paid Filters and/or Buyer Filters, CAKE has introduced the flexibility to configure at multiple different levels.
To skip a filter at all levels, regardless of if it is set as a Paid Filter (Vertical or Campaign) or as a Buyer Contract Filter, follow these steps:
- Navigate to the Setup main tab
- Navigate to Filter Types sub tab
- Click the Add button to create a new filter or double click the row to adjust existing filter
- Check the box titled "Exclude From Eligible Buyers"
- Click Update to save
- Ensure the enabled indicator shows green
To override the filter setting at the Vertical or Campaign levels, follow these steps:
- Open the Vertical or Campaign card
- Navigate to Filter/Paid Filters tab respectively
- Click the Add button to apply a new filter or double click the row to adjust an existing filter
- In the Exclude From Eligible Buyers dropdown, select the desired option:
- Yes = skip the filter on the F.E.B request
- No = run the filter on the F.E.B request
- Default to Filter Type = adheres to what is set on the global filter level
- Click Update to save
To override the filter setting at the Buyer Contract level, follow these steps:
- Open the Buyer Contract card
- Navigate to Filters tab
- Click the Add button to apply a new filter or double click the row to adjust an existing filter
- In the Exclude From Eligible Buyers dropdown, select the desired option:
- Yes = skip the filter on the F.E.B request
- No = run the filter on the F.E.B request
- Default to Filter Type = adheres to what is set on the global filter level
- Click Update to save
How Do I Interpret The Find Eligible Buyers Response?
The initial request/ping will return the Find Eligible Buyers response. Page owners are encouraged to store the entire response but specifically need to store the following fields in order to proceed with a subsequent consent post.
- guid - CAKE's unique identifier for the F.E.B ping request. This id will be used to marry the lead with the consent post using ckm_guid.
- buyer_contract_id - The CAKE buyer contract ids eligible for the lead. After consent, these ids will be used to route the leads to the appropriate buyers using ckm_consent_id.
- consent_option_name - Your buyer's name to be presented on-page to the consumer. Compliance requires this be the exact buyer name that would be contacting the consumer.
- consent_option_tcpa_language - Your buyer's TCPA language to be presented on-page to the consumer. Compliance requires this be the buyer's specific TCPA language the consumer must opt into.
- lead_id - (Optional) Can be used to update the lead before or after the consent post with additional information. See Lead Update Method for details.
How Does CAKE Order Eligible Buyers?
By default, the group and position number shown in the F.E.B response is organized with your highest paying buyers first. This is unless you have configured your CAKE system to use rank and priority instead of buyer price. CAKE intentionally does not provide the buyer's bid amounts within our response.
How Do I Present Eligible Buyers To The Consumer?
Page owners will determine the user experience. For instance, they will determine when in their funnel it is appropriate to fetch and display the eligible buyers on page, how many buyers to display, in what order, etc. Generally, clients tend to make this request to CAKE when they are about to display the phone number field to the consumer.
How Do I Support Lead Aggregators/Brokers With Multiple Sub-Bids?
CAKE recommends that you capture the entire response from the aggregator using the Buyer Consent Name Token (see next section for details). As the page owner, you are then responsible for parsing through this entire response to extract the individual bid ids (referred to as a sub-bids). On the consent post, pass the CAKE buyer contract id for the aggregator and a comma to delineate multiple aggregators. Within each aggregator, use a colon symbol to delineate the sub bid id and a pipe to separate multiple sub bid ids.
Example:
- ckm_consent_id=123:ABC|DEF,456,789:HIJ
Interpret as:
- Buyer contract id 123, sub bid ids ABC & DEF
- Buyer contract id 456 (no sub bids)
- Buyer contract id 789, sub bid id HIJ
In the buyer's delivery method, use the token #sub_bid_id# to map the associated value back to the buyer.
Example:
- Mapped on buyer contract id 123 will return value ABC,DEF (comma separated)
- Mapped on buyer contract id 456 will return a null value
- Mapped on buyer contract id 789 will return HIJ
What is Consent Hierarchy?
Additionally, CAKE enables users to configure a consent hierarchy within the system. This allows the response to include the buyer's specific name (instead of the CAKE assigned name) as well as their associated TCPA language crucial when presenting the consumer with the opt-in choices.
The consent hierarchy operates across three levels and will be evaluated in the following order:
- Fetching dynamically from the buyer contract's endpoint*
- Hosting buyer contract-level consent information within CAKE.
- Hosting buyer-level consent information within CAKE.
Note:
*In order for CAKE to fetch the buyer name and/or consent language dynamically, the Fetch Consent setting on the buyer contract or buyer card must be enabled and you must also be using regex tokens to capture the information in CAKE. The Fetch Consent setting is located on the Buyer Contract or Buyer card > Consent tab.
How Do I See Which Buyers Have Consent?
CAKE has introduced new features within the UI for ease of consent visibility. They include:
- An indicator column in the Leads by Affiliate Report
- An indicator column in the Leads by Buyer Report
- A Consent box on the Lead Card with the names/hyperlink of the consented buyer contract(s)
FAQ
If I skip validation or paid filters, does CAKE still evaluate them on the consent post that follows the F.E.B request?
Yes, any field validation or paid filters configured in the system will continue to be evaluated on the consent post. The new settings give customers flexibility to choose if they want to enforce those same filters/validation rules on the initial F.E.B request as well.
Can I pay for non-consented leads?
If you are using a Hosted type offer, CAKE is currently running its payout logic on the initial Find Eligible Buyers request. We will be making an enhancement for Hosted type offers to run payout logic on the consent post in early January 2025.
The setting is enabled, why am I still not getting the Find Eligible Buyers response?
Common reasons why no eligible buyers are returned include:
- There are eligible buyers, but the lead itself is not passing validation, paid filters and/or required fields
- There are no eligible buyers to return because: they are all inactive, do not have an active schedule, are capped, the lead does not pass their buyer filters.