The ARM Industry is extremely competitive, highly regulated, and hyper scrutinized. This competition pushes ARM businesses to quickly adopt new technologies, frequently adapt to change, listen to clients’ needs, and continuously study the market. Furthermore, the high degree of regulation that permeates the debt recovery industry lends itself to unintentional violations.
Below are suggestions when considering compliance and operating a dialer.
1. 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.
2. Take advantage of the training, meeting and compliance services provided by ACA International and related industry trade associations.
3. Use services like Cell Scrub to identify cell phone numbers, so they aren’t dialed via an auto-dialer without permission.
4. Don’t presume your dialer partner will simply know how you want the dialer to operate. Work hand-in-glove with them to set up your dialing parameters and campaign management strategies. Educate your vendor partner on your policies, procedures and clients’ requirements.
When establishing your dialer rules, carefully consider your current contacting methods and how the dialer fits in:
- Does your company leave answering machine messages? If yes, then what message and how often?
- What do you do with an unanswered call? When do you call it back? I suggest you read Jeryl Smith’s post, “Do you know how many times you have called me today?” for insights on how to minimize potential dialing mistakes.
- Do you dial POE (place of employment)?
- Do you dial relatives in an attempt to locate the debtor?
- How will you route answered calls? Pooled or cradle-to-grave collection environment? Language spoken?
- Will you use Right-Party Identification with IVR messaging 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.
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 DialerFan, a champion of the collection industry, focused on improving collection capabilities through technology and political action. He energetically participates in lobbying efforts for the industry through donations, writing letters, making phone calls, participating in seminars and attending events in Washington D.C., including the most recent ACA International Fly-In.
Well acquainted with debt collection, 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.