What is the effect of the FSA rules on lead generation activities?
We are aware of at least three different methods for producing the leads needed for cold calling. We set out below how we believe the qualifying credit promotion rules affect each of these. Consumer response information The first method involves the firm using lists of consumers who have expressed interest (to a third party not directly connected with the firm) in receiving information or advice on how to review their mortgage arrangements. The lists are usually sold by organisations (which comply with the Telephone Preference Service or Mail Preference Service guidelines) that collect data through lifestyle questionnaires. The firm uses these lists to make telesales calls to consumers. If the consumer agrees to a review then a home visit invariably takes place. Typically, the outbound call follows a script that includes appropriate disclosures. As long as the consumer has expressed an interest in receiving information or advice on reviewing his mortgage (or other qualifying credit) ar