by Karl Walder | EVP of Innovations | June 10, 2019

On Tuesday, June 5th, the Consumer Financial Protection Bureau (CFPB) announced a proposed update that “would provide consumers with clear protractions against harassment by debt collectors and straightforward options to address or dispute debts. ” In an effort to combat illegal robocalls, the senate also passed legislation called the Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act which would allow carriers to use various algorithms to identify phone numbers that are not legitimate, label them with a warning, or block them all together.
  • Establish a clear rule limiting call attempts and telephone conversations: once a conversation has taken place, the debt collector must wait at least one week before calling again.
  • Clarify how debt collectors communicate- using Voicemail, Email, and SMS-  with consumers.
  • Provide guidance to unsubscribe to these methods.
  • Debt collectors can to call up to only seven times a week; can use text, email, and private message to try and obtain payments.

Tip #1: Register Your Outbound Phone Numbers

Calls can be blocked or labeled incorrectly.Register your numbers in the carrier ecosystem. The most convenient way is to use a telco provider that can include this when you order and provision your phone numbers:

  • The phone number must be owned by the initiating called party and registered with the carrier ecosystem.
  • You only have seven calls per person per week. Use seven numbers available in the local exchange as part of your rotation strategy.
  • Use a Local Caller ID. By pulsing out a local DID as your Caller ID, this still provides a higher probability of caller picking up or returning call.
  • Changing the Caller ID per attempt shows promise for maintaining the contact rate.

Tip #2: Ringless Voice Mail

Most of us already set up our phones to screen “Unknown Number” so our phones do not ring. Given that most illegal robocalls do not leave Voicemail, look into Ringless Voicemail:

  • It leaves a message without a sound.
  • Customers do not like interacting directly with agents. Some mobile services will even transcribe the message and include a specific callback phone number that can either be tied to the Caller ID used or list a separate phone number
  • Use a separate phone number in the message to determine how many consumers are returning the call.

Tip #3: Inbound Return Calls

 Each number used should have any returned call routed back to a call queue that will send the calls to the team responsible for the workflow. Best practices we have observed include adding in the follow capabilities:

  • Prior to the call entering the queue, look up the caller information to determine where their place in the collection’s workflow.
  • Once the caller is recognized, create an IVR- or self-service option- to complete the transaction with a self-service request for payment.
  • Use the same lookup to derive the skills or team that should answer the call.

Tip #4: SMS Text Messaging

Use SMS as Part of Your Account Ownership Workflow

  • Similar to the inbound ANI lookup, the agent application can query your phone number type data base to determine if the number is a mobile device.
  • The collector can now use SMS as an additional communication technique to message the debtor of payment reminders or any other type of follow up.

Build your permissions and let customers know about this option.

  • This also keys off the Automatic Number Identification (ANI) lookup of the Inbound Phone Call.
  • Determine if the caller is using a mobile phone by using an external data lookup to see if the ANI is assigned to a mobile phone user.
  • Send a caller an SMS message with another self-service option to a web page with a payment or resolution option.
  • Once SMS is established as a communication option, this opens the door for SMS outbound campaigns.
The NobelBiz Innovations Team works diligently to assure your contact rates are enhanced or maintained as this legislation evolves to assure you get those hard-fought promise to pay and payments.
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