National Electronic Payments Month

Finding a Winning Formula for Predictive Dialing

Steps taken in a collection campaign with a predictive dialer must be cautious ones. The authority of the CFPB and dated nature of the TCPA have made the use of a predictive dialer a gamble in the eyes of many collection professionals. However, given the efficiency of a dialer, many collection professionals cannot help but simply proceed with caution. This has led to many philosophies when it comes to using a dialer. Each collection agency seems to have their own unique sauce when it comes to establishing sound compliance strategy.

patterson lex2“In today’s environment a true dialing philosophy begins with risk assessment,” said Lex Patterson, president of DAKCS Software Systems. “Each scenario can then be mapped according to the desired outcome. Begin with an internal assessment and ask yourself these types of questions:

• Do we have “prior expressed consent” to dial cell phones?

• Is there a way to gain expressed consent on cell phones through our clients’ initial contact with the consumer?

• Are we verifying the consent and best form of communication on every call?

• Are we scrubbing for cell phones and isolating them in the system?

• What is our process to handle wrong or reassigned numbers?

• If choosing to leave messages on voicemail, what is the appropriate message to leave?

• Should we be leaving messages on answering machines?

“Although it will take time to re-evaluate your operations and call handling, it will help in maintaining compliance as well as providing key performance indicators you will want for measurement, analytics and tracking results. Once you have your process map complete, building a workflow that optimizes contact results while minimizing the risk of non-compliance can be more easily achieved and successfully evaluated.”

Asking the correct questions can certainly put an agency on the correct path. However, compliance is a moving target. Once a winning formula has been implemented for predictive dialer efforts, a new rule on increased concern may surface. Working with the leadership and compliance teams is key at this point.

bird terrel“Communicate,” said Terrel Bird, CEO of TCN. “Without giving advice on what you should do, I think it is important to communicate with debtors, agents, management teams, and attorneys alike. This will allow an open dialogue with all parties if a dispute were to come up. It also will alleviate the pressure agents put on debtors.”

Developing a philosophy for the compliant use of a predictive dialer is a difficult task every collection agency must undergo. It is a reminder that successful debt collection without compliance is an impossibility.