Welcome to the Research Assistant Weekly Newsletter - a subscriber-only resource for insight into emerging compliance challenges, details on peer calls, and links to new Research Assistant reports, documents, tools, and more.
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In this week’s Research Assistant Peer Group meeting, we discussed how members who are using text messaging to send consumers their Model Validation Notice (MVN) are navigating the challenges that come with it.
Regulation F introduced both the MVN and the requirements for using modern communication channels like text and email. However, it also made clear that placing the MVN behind a link, login, or portal is problematic.
Text messages are limited by character count. They must also include opt-out language and a simple opt-out mechanism. This makes it nearly impossible to include the full MVN content, the tear-off portion, and any required state disclosures directly within the body of a text message.
So, what’s working for our members?
The most common approach is sending the MVN as an image, either a single long image or two images representing both pages. This allows the required content to be delivered without sacrificing formatting. The body of the imaged text message can then include a link to your portal or website, opt-out language, and any additional instructions.
Is it perfect? No. But for most, it’s a practical solution that works.
When considering this communication method ensure you send MVNs via text only to numbers you reasonably believe are the consumer’s personal cell phone. Avoid employer-provided numbers or any obtained solely through skip tracing. You should have a high level of confidence that only the intended consumer will receive the message. Numbers provided directly by the consumer, either to the creditor or directly to your agency in prior conversations, are generally safest, especially when further validated through tools like reassignment number database scrubs.
The common consensus was, leverage technology, but use it wisely. Done right, it can enhance consumer communication and keep your agency in compliance.
Documents and Crowdsourced Materials:
Top Reads:
Upcoming Webinars/ Other Announcements:
- Next RA Compliance Corner Webinar June 5th – Mark Your Calendars… Details Coming Soon!
- Important Announcement: All AI Notetaking Bots will be removed from Research Assistant Peer Group Meetings. This is to maintain the confidentiality of our peer members.
- Have topics you want to discuss during the peer call? Please send them to Sara_Consultant@roundtables.us by Thursday to ensure it makes it on our agenda!
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