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Compliance: Keep it at the Top of your Dialing Strategy
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Compliance: Keep it at the Top of your Dialing Strategy

February 12, 2013
By TMCnet Special Guest
Dave Rudd

Today, dialing technology is something very few ARM (News - Alert) agencies can succeed without. In an extremely competitive, highly regulated and hyper scrutinized industry, ARM businesses must study the market for the dialing technologies that will give them a needed edge without compromising their compliance efforts.  

Most dialing technology vendors have included compliance features, including legal calling hour settings, cell phone scrubbing and call recording. But just because your dialing technology is compliance capable doesn’t mean you’re automatically following all the regulations by using it.

ALWAYS involve your corporate counsel in your collection/dialer operations and procedures. Your attorney is perhaps your best friend in guiding you along the compliance path.

Likewise, communicate with your dialer partner. Don’t presume your dialer partner will simply know how you want the dialer to operate. Educate your vendor partner on your policies, procedures and clients’ requirements, and work hand-in-glove with them to set up your dialer to meet your operation goals and compliance comfort level.

When establishing your dialer rules, carefully consider the available features based on your current practices and compliance expectations:

  • Answering machine messages: Will you leave them? If yes, what message and how often?
  • Unanswered calls: When will you call back? Will you dial another number in the account, such as POE (place of employment)?
  • Account ownership: Will you work accounts in a pooled or cradle-to-grave environment?
  • Call Routing: Will you route calls to the appropriate agents based on language, account type/balance or another factor?
  • Cell phone scrubbing: Will you identify and exclude cell phone numbers, so they aren’t dialed via an auto dialer without permission?
  • Right-party identification: Will you use an IVR message to properly identify the debtor?

Also, make sure to do the following:         

  • ALWAYS encrypt sensitive data (i.e., credit card and medical information).
  • ONLY submit data to the dialer that is actually needed for dialing!
  • Implement a real-time interface with your host collection system in order to have the most accurate data as your campaigns dial.
  • Take advantage of the training, meeting and compliance services provided by ACA International and related industry trade associations.

Competition, dialer compliance and regulations are constantly changing. You must be vigilant in keeping current on these changes and managing your dialer for compliance, so that you can avoid unnecessary regulatory challenges.

Dave Rudd is a champion of the collection industry, focused on improving collection capabilities through technology and political action. Dave spent two years debt collecting before joining IAT in 1990. He has held a variety of positions at IAT — a provider of collection-specific dialing technology — including President/CEO and most recently Senior VP of Finance & Administration.

Edited by Braden Becker

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