Free registration is required to access these resources. Login or Register.

Premium compliance products are also available in the insideARM Store

Dave Rudd

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.


Related Products

Telephone Communication Compliance: The CFPB's Consent Orders Thumbnail

Telephone Communication Compliance: The CFPB's Consent Orders

Our Telephone Communication Compliance: The CFPB’s Consent Orders guide is designed to help debt collectors comply with consent orders that hint at telephone communication violations. The report includes easy-to-understand explanations of each consent order and a comprehensive chart of all relevant consent orders, keeping the information you need right at your fingertips! This paper has been excerpted from insideARM's larger "The CFPB's Consent Orders Regulating the ARM Industry" report, available for sale now.

Staying Compliant – and Out of Court – with the TCPA Thumbnail

Staying Compliant – and Out of Court – with the TCPA

This reference guide distills the information presented in our webinar. It comes complete with a link to the full recording of the webinar – great for use for all-staff trainings and quarterly in-services -- as well as the slide deck and full transcript of the webinar. This guide doesn’t just walk through what agencies should and should not be doing, going forward -- it contains the full Q&A from the webinar, too. (This product is approved for DBA International Certification Credit.)

The CFPB's Consent Orders Regulating the ARM Industry Thumbnail

The CFPB's Consent Orders Regulating the ARM Industry

Our guide on The CFPB’s Consent Orders Regulating the ARM Industry is the first report of its kind designed to help debt collectors comply with consent orders. The report includes easy-to-understand explanations of each consent order and a comprehensive chart of all relevant consent orders, keeping the information you need right at your fingertips! This report will be updated quarterly.

UPDATED! CFPB’s Advice to the Consumer (through March 2016) Thumbnail

UPDATED! CFPB’s Advice to the Consumer (through March 2016)

The Consumer Financial Protection Bureau hosts more than 80 of the most common consumer questions about debt collection on its Ask CFPB website. And since the Bureau was created for the sole purpose of representing and protecting consumers, debt collectors need to know how the CFPB communicates with them. That’s why insideARM compiled the answers to all 88 questions in one user-friendly report. Using the CFPB’s guidance as a model for your own compliance priorities, policies and procedures means your company will be able to keep up with the Bureau before it feels the need to examine your agency. ALL ANSWERS UPDATED THROUGH MARCH 2016.

Advertisement