TCPA consent for life insurance leads after the one-to-one rule was vacated

What happened to the one-to-one rule

The FCC's one-to-one consent rule was vacated by the Eleventh Circuit on January 24, 2025, one business day before it was due to take effect. In Insurance Marketing Coalition v. FCC, the court held the FCC exceeded its authority by requiring consent to name a single seller and to be "logically and topically related" to the original interaction.

The rule would have ended the practice of one form granting consent to a long list of buyers. Without it, those forms are not automatically unlawful, but they are not safe either.

Why the agent still carries the risk

The Telephone Consumer Protection Act still requires prior express consent for autodialed or prerecorded marketing calls and texts, and lets consumers sue per call. The person or company that places the call is the one named in the complaint. A vendor's assurance that the lead "opted in" does not help if you cannot show what the consumer agreed to, and to whom.

For the general picture across home services and restoration, see our note on shared leads and TCPA consent. This is not legal advice. Your counsel should approve the consent language you use.

A consent standard that holds up

• Name your agency in the consent text, not a "marketing partner" list.
• Record what the prospect saw: the exact language, the page URL, the date and time, and the ad or source that brought them.
• Store it with the lead in your CRM, so anyone who calls can find it.
• Honor opt-outs fast across calls, texts and email.

Leads generated in your own accounts make this easy, because you control the form. For bought leads, ask for the same records before you dial. See exclusive vs shared IUL leads for the vendor checks.