We have sad news this week — lead generation is dead.

An FCC ruling finalized in 2023 will change lead generation as marketers know it in the new year.

Lead generation and SMS robocalls are going away, but Connection Holdings CRO David Stodolak shared his plans for a pivot in 2025, and savvy marketers can make the same moves now — before it’s too late.

Losing the Lead Gen Loophole 🕳️

The FCC ruling closes the so-called lead generator robocall loophole by establishing rules that state:

  • Calls and texts from sellers must be logically and topically related to the opt-in notice they agreed to
  • Numbers on the federal do-not-call registry are excluded from SMS
  • “Clear and conspicuous disclosures” for one-to-one consent
This last point might be the most impactful. Instead of opt-in language that authorizes consent for offers from more than one company on a page, marketers are now limited to asking for consent only for the business listed in the notice.
The new opt-in language

This rule change is going to seriously impact marketers, lead aggregators, small businesses, and other industry stakeholders, but there are also opportunities to capitalize on as the lead generation market is in flux.

The biggest winners in this change, David says, will be lead generation through Pay Per Call, which will still be compliant under the new FCC rules. To make Pay Per Call work in an increasingly competitive marketplace, however, you’ll need to follow a few guidelines:

1. Watch Your Money 🤑

As Pay Per Call grows, you’ll need to monitor your call centers for accountability and quality assurance. Some call centers can roll hundreds of calls a day, and the value of those leads is not to be taken lightly. Ensuring that your teams are maximizing every opportunity is crucial in the Pay Per Call space.

2. Extend Your Net 🕸️

Longer payment terms can be extremely beneficial for scaling and sustaining Pay Per Call campaigns. Many advertisers will offer short-term deals like Net-30 or Net-15, but you can negotiate longer terms based on leverage from positive campaign performance or exceeding KPIs.

3. Retain a Good Attorney 🧑‍⚖️

One outcome is guaranteed under the new FCC regulations: lawsuits.

Law firms and government watchdogs will be zealously pursuing advertisers, marketers, and organizations that fail to comply with the new rules. And even if your Pay Per Call or other campaigns are on solid legal grounds, there’s a strong possibility that your successful lead generation will draw the attention of these entities.

In this hyper-litigious landscape, having an attorney ready to respond and protect your campaigns will be essential to keeping your business going and preventing competitors from conquering your market share.

4. Monetize Aged Leads Now 💎

Aged leads and first-party leads that are still in your system need to be monetized as soon as possible because reaching out to those leads won’t be allowed anymore when the new FCC rules go into effect.

Leads that don’t have one-to-one consent for their opt-ins are still valuable if you can reach them before the end of 2024. But the value of that data won’t last forever, and you’ll need to leverage it now as you prepare to pivot into the new world of lead generation.