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.
During our recent Research Assistant Peer Call, an interesting issue was raised: If a bot requests the removal of a phone number, should it be considered as coming from the consumer? One of our members shared an experience where they received an automated bot response, asking for the phone number used to be removed from their call list.
The discussion focused on whether such a request, coming from a bot rather than the consumer directly, should still be treated as valid. While one could argue that it wasn’t the consumer making the request in person, is that a stance we want to take? As an industry, we’ve spent considerable effort convincing regulators that modern technology, like automated messaging systems, is a legitimate way to communicate. Given that, shouldn’t consumers be allowed the same technological convenience when communicating with us?
Legal perspectives were also considered during our discussion. Some attorneys recommended honoring these automated requests. They pointed out that consumer protection agencies, such as the CFPB, often emphasize honoring the consumer’s preferred method of communication most desired by the consumer.
Considering that Generation Z and Millennials are tech-savvy, the use of bots, automation, and texting has become inevitable in modern communication. It is essential for all of us to stay updated and embrace technology, so we can continue to find effective ways to engage with consumers and address their legitimate debts.
Looking at the future, due to automation, there will likely be less conversations directly with consumers, which could lead to an increase in lawsuits for collecting valid debt. We’ve seen similar cycles in the past with restrictions on exemptions and garnishments, property and judgment renewals, statute of limitation time frames, the list goes on. Despite these shifts, lending continues, bills are still created and over time, hopefully, it will correct itself to some extent. We see regulators continuously over correcting from one extreme to the other instead of working on a viable balance.
Physical mail remains an option for maintaining communication, provided a cease-and-desist order hasn’t been issued. Though it may not be the most efficient or cost-effective method, it still serves as a viable channel. Remember to follow state laws, as some impose restrictions when sending physical letters.
Documents and Crowdsourced Materials:
Top Reads:
Upcoming Webinars/ Other Announcements:
- RA Compliance Corner: Managing Your Service Providers- Do you really have it all in order? September 25, 2024 at 2PM ET. Register here.
- 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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