Almost every bank either operates its own contact, or call, center or commissions a third party to do so. As consumers increasingly prefer to interact with their banks online and via mobile apps, contact centers remain critical for customer outreach as well as inbound service support. For many of the bank’s self-service customers, this may be their sole means of personal interaction, so accuracy in account data and general operational efficiency are key to any contact center’s effectiveness.
The accuracy issue is particularly important because outbound calls made to incorrect or outdated phone numbers can run afoul of stringent enforcement of the Telephone Consumer Protection Act (TCPA), which can cost banks heavily in fines. Capital One Financial Corp., for example, recently paid $73 million into a fund to settle a combined class action suit over claims it used automatic dialing systems to call consumers on their cell phones without consent.
Established in 1991, TCPA was updated, effective October 2013, to prohibit banks and other businesses from contacting consumers via phone call or text message without proper written consent from the customer. The law’s penalties can range from $500 to $1,500 per violation, which is how organizations like Dish Network and Capital One accrued such enormous fines. The Federal Communications Commission (FCC) is able to bring additional enforcement action with penalties of up to $16,000 per violation.
Phone Number Recycling
Beyond the updates made to TCPA, the recent surge of fines and settlements making headlines can largely be attributed to the rapidity with which phone numbers are now recycled. In 2011, the FCC reported that 37 million phone numbers are recycled each year. This occurs when consumers change to a new carrier or shut down a landline, which we all know is becoming more common. We can only expect that this number has risen considerably with more consumers primarily using a mobile phone. The National Center for Health Statistics, an arm of the Centers for Disease Control (CDC), reported that as of July 2014, two out of every five U.S. households utilize a wireless phone only. Once a landline is shut down, a mobile provider can pick it up and recycle it after just 90 days. Adding to the complexity, VoIP numbers can now be transferred to mobile numbers as well.
At this rate, accurate phone numbers have become a moving target, and thus a very difficult matter for contact centers. According to our internal study, customer data from 2011 had a more than one in 10 chance of providing a mobile number that no longer belonged to the same person. Now, four years later, the challenge that number recycling poses is inevitable, making it vital for banks to identify an accurate way to verify before they make outbound calls.
The modern contact center, in an effort to avoid TCPA risk and customer frustration, should be equipped to verify, in real time, the phone number before a call is even placed. Even if a bank enlists a partner for its contact center, the financial institution is by no way excused from liability in the third party’s actions. And, it is common now for third parties to better protect themselves in the initial agreement against wrong number calls.
If a text message is sent, for example, on behalf of a bank or another organization (even if it was not aware or did not authorize the message) simply the inclusion of the bank or company’s name in the text message subjects it to TCPA litigation. Regardless of whether the bank or company has implemented procedures specifically to prevent these violations, wrong number calls made by business partners can be ignored completely by TCPA plaintiff’s attorneys.
To avoid risk of exposure to TCPA penalties, contact centers must look beyond determining whether each number is valid. They must also ensure it belongs to the correct subscriber and that the account is active before dialing. To accomplish this, contact centers need real-time access to mobile phone data as well as a method for cross checking this data against phone numbers across the U.S. Modern contact centers can no longer rely on a bank’s database; instead, they need visibility across the mobile networks. With so much movement among phone numbers, they need immediate access directly from the mobile network operators to information regarding changes to account information or phone numbers.
When it comes to TCPA and compliance in general, the objective of virtually every bank is to balance requirements without sacrificing efficiencies or customer service. While TCPA fines are most often the initial driver for banks to adopt solutions to improve their contact centers, institutions are finding that contact centers might not necessarily need an entire overhaul. Instead, achieving desired outcomes requires contact centers to undergo a database clean up. Updating their CRM data and using tools available for automatically verifying calls is the optimal way for banks to avoid wasting time calling the wrong numbers while meeting TCPA compliance and reducing customer frustration.
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