Lead Consent Authorization Guide

Lead Consent Authorization Guide

Overview

The FCC has decided to delay the implementation of the One-to-One Consent Rule by one year to January 26, 2026.


Welcome to our comprehensive user guide on configuring the new communication consent settings in Infinity Software, designed to comply with the FCC's one-to-one consent rule. In this video, we'll walk you through the step-by-step process to enable and set up these settings in your system. First, we'll review the default communication settings, then delve into modifying customer site settings and loan types. We'll also illustrate how customers will interact with the newly added communication consent page. Finally, we'll demonstrate how to verify these settings in a customer's profile. 


Step 1: Verify Default Communication Settings

Before configuring the Communication Consent Page, it’s essential to check the current default behavior of your communication settings. This includes reviewing the Default Contact Methods in your system to ensure that emails, text messages, and phone calls are all unchecked. This verification step ensures that communication methods are not pre-enabled without customer consent, aligning with compliance requirements.

To be safe, it’s recommended to verify that all communication methods for all required customer fields are disabled by default. This approach prevents pre-enabled methods and ensures that consent is explicitly granted by your customers. Here is a list of the Settings pages for all types.

1. Customer Site Required Fields – General

  • Located in Settings > Required Customer Fields (Customer Site)
  • Ensure that the Default Contact Methods for emails, text messages, and phone calls are unchecked.

  • This setting applies to organic customers who apply directly to your Customer Site.

2. Customer Site Required Fields – Loan Type Specific

  • Loan types connected to Customer Site Settings may have dedicated required fields.

  • Navigate to Loan Types in Settings to verify and disable Default Contact Methods for emails, text messages, and phone calls specific to that loan type.


  • This setting applies to organic customers who apply directly to your Customer Site, but are defaulted to a Loan Type with dedicated Required Customer Fields.

3. Required Fields for Leads – General

  • For lead customers redirected from a lead provider, review the Required Customer Fields (Leads).

  • Verify that Default Contact Methods are also disabled to ensure communication methods are not pre-enabled by default.

4. Required Fields for Leads – Loan Type Specific

  • Leads may be associated with specific loan types based on the POST specs you have set up with your lead provider:

  • Navigate to Loan Types in Settings and verify the required fields for leads tied to that loan type.

  • Disable the Default Contact Methods.

Step 2: Update Customer Site Settings


  1. Enabling the Customer Consent Page

    • Click the Blue Pencil Icon for the setting associated with your customer site.
    • Scroll to the Loan Application Sequence section.
    • Enable the Communication Consent Page:
      • Select whether the page should be visible to:
        • Organic customers
          *Note - If you are already collecting Text Message Consent in your Loan Application settings (i.e. Required Customer Fields (Customer Site)) as well as Email and Phone consent via your Loan Agreement, the recommendation is to disable this checkbox for organic customers.




        • Lead customers
        • Adjust the sequence to display the Communication Consent Page as the first step for new and returning customers.


Configure Communication Consent Options and Verbiage

  1. For each communication method (e.g., text messages, emails, phone calls):
    • Enable the specific communication types (e.g., loans, collections, marketing) that an opt-in consent will enable within a customer's contact methods.


      • Note - Text Message consent will have two conspicuous, dedicated opt-in checkboxes by default. The verbiage for this consent authorization is locked in order to maintain compliance.

  2. Make sure that you consult with your compliance and regulation team for proper guidance for Phone and Email consent language, and that your verbiage matches the communication consent collected in the settings.



  3. Configure the placeholders (e.g., store name) linked to your Privacy Policy URL and Terms of Service URL

    1. Privacy Policy and Terms of Service URL should be a link to each of the corresponding documents.
    2. Privacy Policy and Terms & Service Link Text fields will be the hyperlinked text that will display on the Text Message Authorization section.

FAQ

As of now, there is no dedicated output specifically for timestamped disclosures that summarize a customer's communication consent actions. However, you can review the Customer Detail History to see the initial communication settings (contact methods) the customer came in with and the changes made during the consent process.

We are actively working to enhance this functionality and plan to include a dedicated timestamped disclosure feature in a future update. This will streamline tracking and provide a comprehensive output for audit and compliance purposes.

Which store is populated for the Text Message portion of the Communication Consent Page?

The store placeholder displayed on the Communication Consent Page depends on the customer's method of entry and is controlled by the store set in Customer Site Settings for New Loans and Reloans.

  • For Leads:

    • If the StoreID is passed with the POST request for the lead, the placeholder will reflect that store.

I don’t know the links to my Text Message Terms of Service or Privacy Policy page. Where can I find them?

These links should have been set up on your behalf during the configuration of the Customer Required Field settings. If you are unable to locate the URLs, please reach out to your CS Rep or call for assistance in retrieving this information.


If I’m using the Communication Consent Page for text message communication for organic customers, isn’t this a duplicate consent collected from the Customer Required Field added to my application?

This text message communication consent section will only display twice to organic customer site applicants. If your loan agreement already includes communication clauses, you can streamline the process by selecting the Leads-only option when configuring the Communication Consent Page. This avoids unnecessary duplication while maintaining compliance.


I'm not sure if I have any communication clauses in my Loan Agreements, how would I check this?

Please reach out to your CS Rep or call for assistance in retrieving this information.


Disclaimer:
This user guide is for informational purposes only and does not constitute legal or compliance advice. It is your responsibility to ensure your organization complies with applicable regulations. Please consult your legal or compliance team for guidance specific to your circumstances.

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