Compliance Framework

Compliant by Design.
Not by Checkbox.

Every lead and call delivered by DemandVertical passes a multi-layer compliance pipeline — TCPA consent, real-time fraud scoring, CMS/HPMS documentation, and third-party verification on every record.

Pipeline Overview

Four Steps. No Exceptions.

Every consumer record moves through this sequential pipeline before being approved for delivery. No step can be skipped.

01

Capture & Consent

Consent is captured at the source, with TCPA-compliant language displayed at point of data submission.

  • One-to-one consent language
  • Timestamp & IP recorded
  • Jornaya LeadiD generated
  • TrustedForm certificate issued
02

Score & Validate

Proprietary technology scores every record across 40+ behavioral and contextual signals in real time.

  • Intent score assigned (0–100)
  • Phone & address verified
  • Identity cross-referenced
  • Duplicate detection applied
03

Screen & Filter

Records are screened against compliance rules before any routing decision is made.

  • DNC / NDNC registry scrub
  • State-level regulatory check
  • Fraud signal evaluation
  • Buyer filter criteria applied
04

Deliver & Document

Approved records deliver with a full audit package attached — every field traceable to its source.

  • Consent certificate URL
  • Full timestamp chain
  • Source & intent score
  • Delivery receipt generated
Risk Scoring

Four-Tier Risk Model

Our proprietary technology assigns a risk score to every record. The score determines routing action before any delivery commitment is made.

Risk Tier Score Range Routing Action Description
Low Risk 80 – 100 Standard Routing Clean record with strong intent signals. Routes immediately to qualified buyers at full price. No flags, no holds.
Medium Risk 50 – 79 Secondary Review Acceptable record with one or more soft flags. Routed to secondary buyers or held for manual spot-check before delivery.
High Risk 25 – 49 Manual QA Required Record exhibits multiple anomaly signals. Held from automated routing. Requires manual QA review before any delivery.
Critical 0 – 24 Do Not Contact Record blocked from all routing and delivery. Flagged for compliance audit. Causes: confirmed fraud, invalid consent, DNC match, or known bad actor pattern.
Compliance Controls

Six-Layer Compliance Stack

DemandVertical enforces compliance at six distinct checkpoints — each automated, each logged, and each independently auditable.

Control 01

TCPA Consent Verification

One-to-one express written consent is required and verified for all data leads and call transfers. Consent language is specific to the buyer receiving the record.

  • Consent language stored per record
  • Certificate URL included with every delivery
  • Retroactive certificate retrieval available
  • 30+ months of audit-ready storage
Control 02

DNC Registry Scrubbing

Every record is scrubbed against the National Do Not Call Registry, state DNC lists, and buyer-specific suppression files before routing is initiated.

  • Federal & state DNC lists updated daily
  • Buyer suppression file integration
  • Internal DNC list maintained
  • Scrub log attached to each record
Control 03

Real-Time Fraud Detection

Proprietary fraud models evaluate every submission for bot activity, recycled data, identity mismatches, and anomalous behavioral patterns.

  • Device fingerprinting at intake
  • Velocity & pattern analysis
  • Known bad-actor database matching
  • Real-time block or quarantine
Control 04

State Regulatory Compliance

State-specific insurance marketing rules — calling hour restrictions, disclosure mandates, and vertical-specific requirements — are enforced automatically.

  • 50-state rule library maintained
  • Medicare AEP/OEP time restrictions
  • Health plan marketing rules enforced
  • Auto insurance state minimums applied
Control 05

Data Integrity & Validation

Phone numbers, addresses, and identity fields are validated in real time against authoritative third-party data sources before any routing action.

  • Phone ownership & line-type check
  • Address standardization & validation
  • Name-to-phone match scoring
  • Duplicate suppression across 90 days
Control 06

Audit Trail & Recordkeeping

A full, timestamped audit trail is generated for every record and retained in a format suitable for regulatory audit, legal discovery, or buyer dispute resolution.

  • Immutable record log per lead/call
  • Source, timestamp, and consent chain
  • Delivery receipt with buyer confirmation
  • Dispute resolution documentation
Fraud Prevention

Fraud Caught at Four Points

Our proprietary technology intercepts fraudulent activity at every stage — before media spend is committed, before routing, before delivery, and after the fact through ongoing monitoring.

  1. 01

    Pre-Submission Detection

    Fraud signals are identified at the moment a consumer interacts with the intake form — before the record is even created. This is the most cost-effective point of intervention.

    • Bot & automated traffic detection via device fingerprint and mouse behavior analysis
    • Known proxy, VPN, and datacenter IP blocking
    • Submission velocity throttling — flags more than 3 submissions per IP per hour
    • Form field anomaly detection (copy-paste patterns, speed-filling)
  2. 02

    Post-Submission Scoring

    Every submitted record is run through our proprietary risk model immediately after intake. High-risk records are quarantined before any routing spend is committed.

    • 40+ signal risk score calculated within 200ms of submission
    • Phone number validity, ownership, and line-type verification
    • Identity cross-reference against known fraud databases
    • Email domain and deliverability scoring
  3. 03

    Publisher-Level Monitoring

    Every traffic source is continuously monitored for quality degradation. Publishers showing elevated fraud rates are flagged, throttled, or suspended automatically.

    • Per-publisher fraud rate tracked in real time
    • Automatic throttle at 5% fraud rate; suspension at 10%
    • Geographic and device anomaly alerts by source
    • Historical pattern comparison against publisher baseline
  4. 04

    Post-Delivery Dispute Resolution

    Buyers can flag delivered records for non-compliance review. Our team investigates within 48 hours using the full audit trail attached to every delivery.

    • Dedicated dispute intake process with SLA
    • Full consent certificate and timestamp chain review
    • Publisher chargeback and remediation workflow
    • Trend analysis to prevent recurring issue patterns
CMS & Regulatory

Built for the Insurance Industry

Medicare and health insurance lead generation carries the highest regulatory burden in the industry. DemandVertical is purpose-built for it.

CMS Marketing Rules

All Medicare campaigns comply with CMS marketing guidelines, including media channel restrictions, required disclosures, and prohibited content rules.

  • CMS Chapter 3 guidelines enforced
  • Prohibited inducement controls
  • Required disclaimer language on all placements
  • Scope of Appointment (SOA) documentation available

HPMS Filing & Documentation

Marketing materials used in Medicare campaigns are tracked and available for HPMS submission by contracted plan sponsors.

  • Material ID tracking per campaign
  • Version control and approval timestamps
  • Archive retention for audit readiness
  • Support for plan sponsor submission workflow

AEP & OEP Scheduling

Campaign volume and outreach are automatically restricted to CMS-permitted enrollment period windows for Medicare Advantage and Part D.

  • AEP: Oct 15 – Dec 7 campaign windows
  • OEP: Jan 1 – Mar 31 restrictions enforced
  • SEP eligibility verification workflow
  • Automated campaign pause outside permitted periods

TPMO Compliance

DemandVertical operates as a compliant Third-Party Marketing Organization under CMS guidelines, with contractual obligations passed through to downstream publishers.

  • CMS required TPMO disclaimer on all placements
  • Downstream publisher TPMO agreements
  • Annual attestation and training program
  • CMS complaints tracking and reporting

ACA & Health Plan Compliance

Health insurance campaigns comply with ACA marketing standards, state DOI regulations, and carrier-specific marketing guidelines.

  • SEP and OEP timing controls
  • State DOI advertising rule library
  • Plan-specific disclosure requirements
  • Agent licensing verification at point of transfer

Auto Insurance Compliance

Auto campaigns adhere to state-specific insurance advertising standards and calling restrictions across all 50 states.

  • State-by-state calling hour enforcement
  • Required rate and coverage disclosures
  • Agent licensing check on live transfers
  • Complaint tracking and escalation workflow
Third-Party Validation

Verified by Trusted Industry Standards

DemandVertical's compliance stack is backed by the leading independent verification platforms trusted by the nation's top carriers, agencies, and regulators.

Jornaya

Independent consent verification — a LeadiD is generated at first keystroke on every form and delivered with each record.

  • LeadiD per record
  • Consent certificate URL
  • Independent audit access
  • 30-month retention

TrustedForm

Session-level recording captures the full consumer interaction — every click, field entry, and disclosure viewed — at time of consent.

  • Session replay available
  • Disclosure visibility confirmed
  • Certificate URL per record
  • Dispute-resolution ready

TCPA Compliance

One-to-one express written consent documented for every lead and call transfer — compliant with FCC TCPA and state telemarketing laws.

  • 1:1 consent standard
  • FCC & state law compliance
  • DNC scrub on every record
  • Calling hour enforcement

CMS / HPMS

Medicare campaigns documented for CMS oversight and HPMS submission by contracted plan sponsors — full material tracking included.

  • HPMS-ready documentation
  • TPMO compliance framework
  • Material ID & version tracking
  • Annual attestation support

Compliance You Can Count On.

Every DemandVertical partner receives full compliance documentation, audit support, and a dedicated account team trained on regulatory requirements.