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Direct Drop Compliance Response

  • Written by David W. Sargent

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I was just forwarded your article titled “Direct Drop, Useful, but may violate TCPA”.  DialConnection offers a suite of products that service the Collection Industry, one of which has been branded DirectDrop.  The technology that you are discussing in your article is not the technology our DirectDrop platform utilizes.  DirectDrop is not a “Dialing” Technology.  Most of the points made in your article would likely be considered a violation of the TCPA.  Additionally DialConnection would never advocate knowingly calling a cell or mobile number using a Predictive Dialer.

Mark Love was able to accurately recite the section of TCPA on auto dialers.  I can say 100% conviction that Dial Connection’s contact center solution is in compliance.

Your article’s talking points centers around the use of Auto/Predictive Dialers used to knowingly ring a cell phone for the sole purpose of having the caller ID show up on that device. Although I am not a lawyer I would recommend staying away from this as a collection strategy.

As far as our DirectDrop offering, we have gone to great lengths to come up with a solution that is compliant and cost effective.  I can only speak to our application with complete certainty but we would never simply dial a cell / mobile device and just hang up.  The two biggest differences in what our DirectDrop service provides vs. what your panel was discussing are the following:

  1. DirectDrop Never Calls the debtors phone.
  2. DirectDrop always delivers an approved and compliant message (FOTI or otherwise).

DialConnection prides itself on supplying creative and technologically advanced solutions for the collection industry; simply having your legacy dialer make phantom calls to debtor’s cell phones is only going to give our industry another target for lawyers.

I have already had our current and potential customers contact me about this article.  I would appreciate it if you can email or get our rebuttal in your next publication.  I have attached our whitepaper and DirectDrop that will correctly answer most of your questions raised in your round table discussion.  In the future we would be more than happy to participate in these types of discussions on technology issues and solutions.

As always thanks again for your time and consideration, I hope that we can inform your readership of what DirectDrop really is and how it should be used.  Better yet give me your cell number and I will provide you with a demonstration of the technology.  Please contact me at your convenience.

Sincerely,

David W. Sargent

Executive Vice President

DialConnection LLC