Take Proactive Measures to Avoid TCPA Violations

August 17, 2015

Since June’s announcement of the FCC’s heightened enforcement of the Telephone Consumer Protection Act (TCPA) robocalling guidelines, financial institutions and other businesses have been looking more closely at their call center risks. Some parties have shared the viewpoint that the FCC’s ruling is unjust to banks and other organizations conducting business the right way, which was evident in a recent American Banker BankThink column entitled, “Why the FCC’s RoboCall Rule is Unfair to Banks,” authored by Henry Pietrkowski of Reed Smith LLP. In his piece, Pietrkowski does a nice job of calling attention to the challenge this new guidance poses for banks.

However, whether or not the ruling is fair, financial institutions will be held liable for any violations. With highly publicized fines proving severe, bank leaders must shift their mindsets and instead of focusing on the rule’s fairness, focus on the solutions available to manage the ruling and prevent TCPA violations. There are ways for financial institutions to be proactive in modifying call center and customer outreach processes while effectively preventing substantial fines from surmounting.

Pietrkowski mentions in his article the challenge most organizations run up against when trying to follow TCPA guidelines: validating consumers’ mobile phone numbers. Today, customers must provide consent to receive calls from their financial institution; however, the rate at which mobile phone numbers are reassigned makes this a nearly impossible task without the accurate data, and in real time. This issue alone is the primary reason that financial institutions will continue to have a difficult time complying with TCPA. Many continue to rely on marketing databases or other sources that attempt to catch the resubscribed numbers; these are simply not capable of providing fast enough validation and leave an organization vulnerable. To avoid operational, reputational and compliance risk, financial institutions must instead have a way to gain access to this critical insight directly from the source: the Mobile Network Operators (MNO).

Early Warning is already helping financial institutions and other businesses improve compliance with TCPA through its direct connectivity to the nation’s leading MNOs. Without this real-time link through Early Warning, organizations cannot truly verify whether a mobile number on file aligns with the correct, consenting consumer. Early Warning’s Mobile Number Verification Service delivers that access, giving users insight into the status of mobile account changes, with updates occurring nearly every two minutes. As mobile numbers are reassigned, financial institutions can be confident that their call centers receive the most accurate information, direct from the MNOs. Other services merely compare caller-ID or port records, collecting data from multiple sources. Early Warning’s single, direct access to a trusted entity enables its solution to track changes within mobile accounts throughout a consumer’s telecom lifecycle is proven, and in a test correctly identified more than 99 percent of mobile changes.

The vast majority of financial institutions that have been and will be fined for robocalling have no ill will, no desire to disrupt consumers or violate their privacy or protection. Regardless, they must identify a way to align outreach methods with the FCC’s most recent guidance. While the only way to accomplish this is by gaining visibility into MNO’s network status updates, Early Warning has already forged these relationships for financial institutions. The Mobile Number Verification Service is empowering financial institutions with 94 percent wireless coverage, reaching more than 297 million customers.

Early Warning understands that a financial institution’s call center activities are a large and important part of its business, and has designed a solution to both optimize those operations and, at the same time, manage the TCPA guidelines set forth by the FCC. Instead of viewing these rules as an unjust requirement, consider the opportunity to enlist solutions that will enhance outreach efforts and strengthen customer relationships in light of it.

To learn more about Mobile Number Verification Service visit http://earlywarning.com/mobile-number-verification.html

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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