We know there's a lot to keep track of right now — evolving rules, carrier requirements, and CRM quirks can feel overwhelming. This article provides some insight into what dealers need to know and do, then shows how Fullpath’s CDP and Lead Handling work together to help you stay organized and reduce risk. Learn more about how Audience Activation and SMS do the same.
Fullpath gives you practical controls, audit traces, and automated protections so you can focus on selling while keeping messaging compliant.
This is not legal advice. For specific legal questions, please consult your legal counsel; for product help, reach out to your Fullpath CSM.
Lead Handling Agent
What to be aware of (SMS consent)
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Marketing SMS sent using automated systems requires prior express written consent that’s specific to SMS marketing (clear, affirmative opt-in).
- Only route or send SMS to leads with documented prior express written consent for SMS marketing — routing without that consent creates TCPA exposure.
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Consent must be recorded (timestamp, exact text shown, source) and stored in your CRM so Fullpath can ingest it.
- Consent must be specific to marketing vs. transactional messages; don’t assume transactional consent covers promotional outreach.
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Consumers must be able to opt out easily (e.g., reply STOP); opt-outs must be honored immediately.
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Consent can be revoked anytime (e.g., by replying STOP); routing systems must respect revocation immediately.
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Consent can be revoked anytime (e.g., by replying STOP); routing systems must respect revocation immediately.
Why this matters
- Improper routing or automated outreach to non-consenting leads can trigger legal claims, fines, and higher complaint/blacklist rates.
- Respecting consent protects customer relationships and keeps messaging deliverability intact.
- Carriers and registries impose registration and content rules — noncompliance can cause blocking or number suspension.
How Fullpath product settings help you align / manage risk
Send gating & opt-in enforcement
- Requires CDP opt-in flag before Lead Handling will route or send SMS; leads without a documented opt-in are blocked from SMS workflows.
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Honors the CDP’s consent state as the source of truth for Lead Handling sends.
Opt-in verification at onboarding
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Fullpath verifies dealership identity and opt-in capture during SMS onboarding (legal name, URL, address, contact, and proof of opt-in language/process) to satisfy carrier/registry checks.
Form & opt-in rules enforcement
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Guidance/validation for lead forms enforced during onboarding:
- Phone number not required to submit form.
- Opt-in checkbox must be optional, unchecked by default, and separated from T&Cs.
- Required opt-in language elements (dealer name, marketing purpose, frequency, not a condition of purchase) are captured for verification.
- Note: By submitting an inquiry, the shopper effectively gives the seller permission to contact them, even if their number is on the National DNC list. The shopper has established what is called an "Established Business Relationship," which overrides the National DNC registry - as long as the lead was generated after the shopper's registration on the National DNC list.
Audience Builder integration (bulk opt-in)
- Lead Handling respects CDP changes: Audience Builder can bulk-enable CDP opt-in and Lead Handling will treat those shoppers as eligible for SMS.
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Audience Builder sends an audit CSV to the CSM with actor, timestamp, and affected shopper list for record-keeping.
Real-time unsubscribe & AI reply handling
- STOP, “DO NOT CONTACT ME” and AI-detected unsubscribe phrases immediately unsubscribe the shopper from SMS within Fullpath; Lead Handling will not route those leads for SMS.
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AI identifies natural-language unsubscribe intent (e.g., “take me off your list”) and triggers polite confirmation + automatic unsubscribe to prevent further messaging.
SMS Replies inbox & manual controls
- SMS Replies page shows inbound messages; authorized users can manually unsubscribe shoppers, review conversation history, and export reply/unsubscribe data.
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Shopper Page surfaces communication preferences (CRM + CDP) for manual reconciliation.
Template, content & frequency controls
- Lead Handling uses AI-generated, personalized templates (name, dealership, vehicle, CTA) to reduce carrier filtering; custom templates must include opt-out language.
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Default frequency rules applied to leads (no more than one SMS per 30 days by default) and default initial send window (2–5 PM ET), enforced across routing flows.
Delivery, number management & blacklist mitigation
- Messages are sent via Twilio; Fullpath acts as ISV and manages toll-free numbers and verification on behalf of dealers.
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The system avoids public link shorteners, enforces personalization, and uses verified numbers to reduce carrier blocking risk.
Audit trails & reconciliation tools
- Audience Builder CSVs, Export Unsubscribed from Shopper Lookup, and SMS Replies exports provide records to support audits.
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Lead Handling checks CDP flags at routing time; combine Fullpath exports with CRM records for a complete audit trail.
CRM sync behavior & limitations (product-relevant)
- Lead Handling relies on CRM → CDP sync cadence. For many CRMs, Fullpath ingests updated preference fields on daily pulls; behavior varies by CRM.
- Fullpath/Lead Handling does not generally write opt-out/DNC flags back into CRMs — unsubscribes processed in Fullpath must be reconciled into the CRM by dealer workflows unless the CRM integration supports two‑way updates.
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If a shopper is enabled for SMS in the CDP but marked DNC in the CRM, Lead Handling will treat the CDP-enabled status as eligible for SMS sends.
Operational safeguards (product controls)
- Permission controls: restrict who can change Audience Builder/Lead Handling settings and who can perform bulk opt-in actions.
- Audit notifications: CSM receives CSV for bulk opt-in/disable actions to document who acted and which shoppers were affected.
Limitations & dealer responsibility (product disclaimers)
- Lead Handling enforces consent checks and unsubscribe handling but does not legally validate the sufficiency of the dealer’s opt-in language — dealers must ensure compliance with TCPA and state laws.
- For CRM-specific opt-out propagation behavior, contact your Fullpath CSM to confirm how your CRM integration handles preference updates.
Need help? Contact your Fullpath CSM for CRM-specific sync details, audit exports, or to review Lead Handling rules. For legal questions about consent wording or TCPA risk, consult your counsel.