New FCC Ruling to Strengthen TCPA - Is Your Organization at Risk?

June 19, 2015

The recent rulings on FCC Chairman Tom Wheeler’s proposal addressing two dozen petitions that sought clarity on how the Federal Communications Commission (FCC) enforces the Telephone Consumer Protection Act (TCPA), closes loopholes and strengthens consumer protections against unwanted calls and texts to wireless phones. These rulings now:

Here are some examples of how we use list blog posts here at HubSpot:Empower consumers to say “Stop”

  • Give the green light for “Do Not Disturb” technology
  • Clarify that reassigned numbers are not loopholes
  • Provide more specific definition of an autodialer
  • Allow very limited and specific exceptions for urgent circumstances
  • Affirm consumers’ rights to control the calls they receive

 As a result of these heightened consumer protections, mitigating operational and compliance risk is of top concern for companies with significant consumer outreach and call center operations. The impacts are wide ranging and will require business line, call center operations, collections, marketing, legal, operational risk and compliance functions to collaborate to adhere to the strengthened standards and requirements.

The key to ensuring that your organization has the proper consent to call or text a mobile number is validating that the mobile number on file does in fact still belong to the consenting consumer.

The Early Warning Difference

Early Warning, which provides risk management solutions to a diverse network of 1,100 financial institutions, government entities and payment companies, has direct connectivity to the Mobile Network Operators (MNOs).

This connectivity enables organizations to verify, in real-time, if the mobile number on file matches the last verification with the consumer. Organizations gain the insight to know if the mobile number on file is a match/no-match based on if there have been changes to the account since the last contact with that consumer as well as the network status of the number (deactivated or suspended).

The ability to verify the accuracy of consumer mobile phone numbers and monitor mobile changes as they occur has become essential in order to mitigate the risks of violating TCPA rules and regulations.

Mobile Number Verification Service:

  • Provides access to over 720 million phone numbers in the U.S.
  • Provides real-time connectivity to Mobile Network Operators with 94% wireless coverage, reaching over 297 million wireless customers
  • Provides Network Status updates in real-time with a data feed of telephone number ports every two minutes
  • Provides tracking of change events throughout a consumer’s telecom transactional life cycle – other solutions only compare caller-ID or port records
  • Requires only a phone number - other services require contribution of phone numbers, names and addresses

In a recent test, Mobile Number Verification Service correctly identified over 99 percent of mobile changes. For example, customer data from 2011 was tested and determined to have a one in ten chance that the mobile number no longer belonged to the same person thereby putting the organization at risk of violating TCPA regulation.

With new rulings to limit unwanted robocalls and spam texts, Early Warning’s model leverages collaborative intelligence in a coordinated effort to protect consumers and organizations. To learn more about Mobile Number Verification Service visit

About the Author:

Ravi Loganathan is chief market development officer for Early Warning’s Regulatory Solutions Practice. He has over 20 years of experience in Compliance, Operational Risk and Marketing Analytics in the Financial Services and Retail sectors.

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