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 Interpret The Find Eligible Buyers Response?
- How Does CAKE Order The Eligible Buyers?
- How Do I Present Eligible Buyers To The Consumer?
- How Do I Know When A Lead Has Given Consent?
- What is Consent Hierarchy?
- 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.
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 buyer(s) 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
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
Note:
Today, any fields that you have set to required or validated in CAKE must be present on the Find Eligible Buyers request to ensure the post is successful. Required fields can be bypassed by using dummy values such as first_name=notyet and updated on the consent post. A feature for skipping required and validated fields will be available early January 2025.
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 The 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 Know When A Lead Has Given 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)
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.
FAQ
How do I support a lead aggregator/broker who returns multiple bids to me?
CAKE recommends that you capture the entire response from the aggregator using the Buyer Consent Name (regex) Token. The page owner is then responsible for parsing through this entire response to extract each individual bid id (sub bid). On the consent post, pass the buyer contract ID for the aggregator then a colon symbol to delineate a sub bid id and comma to separate multiple sub bid ids. Example: ckm_consent_id=123:ABC,DEF. In the buyer's delivery method, use the appropriate token to map the value back to the buyer. Example #sub_bid_id_1# = ABC and #sub_bid_id_2# = DEF
How do I skip validation and required fields on the first request.
CAKE is currently working on a solution for this and will deploy it early January 2025.
Why am I paying for non-consented leads?
If you are using a Hosted type offer, CAKE is currently running its payout logic on this 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.
You may also be interested in:
Related article one (hyperlinked)
Related article two (hyperlinked)
Related article three (hyperlinked)