The DPA license is a must, but it's a cinch to obtain and very cheap.
The CCL is required if you send the leads to a broker and get paid on a back end basis, i.e. if the loan completes. If you simply sell the leads on a cost per lead basis, i.e. you get paid for every lead regardless of outcome, then a CCL is not required. If this were not the case, then every affiliate network would need one, as they are effectively buying and selling leads.
You will read lots of conflicting views on the CCL requirement, and I have no doubt that many other a4u members will contradict my advice above, but having been in the finance lead gen business for over five years I can assure you that my advice is based on 100% accurate facts and not just an opinion.
You will also be told by many others that a CCL helps add credibility and confidence which will lead to better conversions. In our own testing, this has been proven to be groundless - it makes no difference whatsoever.
A merchant buying leads on a CPA basis, either directly or through a third party such as an affiliate network, would neither require nor expect you to have a CCL. A broker/lender paying you on a back end will insist on one and will need proof, which they can check themselves via the OFT.
If you DO decide to go the CCL route, be prepared for a more expensive and time consuming application process than with a DPA.
I hope that helps.
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