As we creep closer at our petty pace, day to day, toward April 11, 2025 lead generators need to be paying close attention to one of the major potential impacts of the new FCC TCPA revocation order.

While enterprise is much more concerned with the “scope” provisions of the new rule crushing their ability to make informational outreach to their customers, lead generators need to be considering these provisions through the lens of ceasing continued marketing after a brand has received a revocation request.

This is a particularly big issue when a brand is buying both data and transfers.

Example.

Major insurance company buys both data leads and transfers from large lead generator.

When a consumer texts “stop” in response to an outreach by the insurance company the company is unlikely to notify the generator of the stop. Yet when the lead generator continues to send messages carrying offers for that insurance company those messages may be viewed as having been made “on behalf” of the insurance company– hence the stop should have been heeded and continued outreach by the lead generator would be illegal.

While a feedback loop between the insurance company and the lead generator in this scenario could avoid this problem–i.e. the insurance company is notifying the lead supplier of the revocations in real time– it is unclear whether that is legal since the CFR bans the sharing of revocation information with third-parties (which is why the R.E.A.C.H. standards have always included a notification that “stop” requests will be shared between buyers of the lead.) So this is a real sticky wicket.

And the problem is even bigger in the context of a lead buyer who is buying data from one source and buying transfers from other sources.

There when a lead buyer receives a “stop” notification it will need to notify not just the lead source–indeed, if the source is not making outbound calls for transfer purposes the data lead supplier need not to be informed at all– but other lead suppliers who may be calling that same consumer on the same or different data.

Suddenly the wisdom of the R.E.A.C.H. model of a hub and spoke approach to lead gen revocation looks very compelling indeed.

Regardless, one thing is crystal clear– brands buying leads and companies generating those leads need to come up with a game plan for April 11, 2025.