The FCC’s 1:1 consent rule represents the most significant TCPA change since the law was first written. As of 2026, consumers must give consent for each individual seller they wish to be contacted by, named explicitly in the consent language.
What changed
Before 2026, a borrower who clicked a ‘lead form’ on a comparison site might have been sharing their information with 50 different lenders, all of whom received that consent as a marketing opt-in. The new rule requires that consent be granted to one seller at a time, with each seller named explicitly.
What compliant consent language looks like
Sample compliant consent: ‘By submitting this form, I consent to receive calls and text messages from [Your Lending Company Name] at the phone number provided, including via automated dialing technology, regarding mortgage products and services. Message and data rates may apply. I can opt out at any time by replying STOP.’ Four required elements: business name, type of communications, mention of automated technology if used, opt-out mechanism.
Impact on lead-buy operations
For mortgage lenders who buy leads from third-party generators, the rule fundamentally changes economics. A lead-gen list with consent obtained for ‘our partners’ or ‘lenders we work with’ is no longer compliant TCPA consent for any specific lender. Each lender must obtain re-consent before contacting purchased leads. This is reshaping the wholesale lead-gen market in 2026.
