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How to Prepare for the CFPB in 2017

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December 14, 2016
By: LiveVox

Managing Massachusetts…………….

For ARM agencies and the businesses they service, Massachusetts is a notoriously difficult state to manage contact attempts. Massachusetts retains one of the most restrictive set of debt collection requirements as shown in the summary on the right.

Managing such requirements can be a logistical nightmare, leaving businesses stuck between a rock and a hard place: invest heavily in ensuring each and every contact attempt requirement is met, or risk costly litigation.

If the CFPB’s 2016 proposal of a limitation of six communication attempts per week is put into effect next year, businesses may be forced to face similar challenges not only in Massachusetts, but across all states.

So … How are some contact centers approaching this challenge?

We’ve seen a myriad of creative ways businesses have approached managing contact attempts, such as a “Dial only Days” approach.

The “Dial Only Days” approach for example, forces contact centers to create silod operations that only allows for dialing selected accounts on specific days, delaying work on other accounts. This of course requires contact center managers to setup and take down restrictions on special days and manually track calendars across all operations, as seen in the calendar on the left.

In this example, a calendar is created to specifically to meet Massachusetts 2 attempts per week requirement. A calendar must be created, tracked, and manage for each month.

While approaches similar to this are quite common, it is manually intensive and cumbersome to manage, putting the agency and the businesses they serve at risk.

Have Agencies Found a More Effective Way?

In 2016, innovative agency leaders turned to cloud technology in search of a more effective approach. Cloud capabilities such as LiveVox’s Phone Dial Attempt Supervisor (PDAS) is a prime example. PDAS allows contact center managers to easily configure dial attempt requirements for states like Massachusetts. Once set, dialing limitations are implemented across the network and cannot be overridden. In essence, PDAS can be used as an automatic stopping mechanism for your campaigns to ensure your operations meet contact attempt requirements.

While currently used for meeting state requirements, PDAS can be leveraged to meet the CFPB’s 2016 proposal, which has been a key driving force in its popularity. In the past 4th quarter of 2016 alone, we’ve seen the adoption rate of PDAS double in preparation of 2017.

How does it work?

The maximum number of dial attempts is easily configurable and can be applied in multiple ways: to an account, to a combination of account and phone number, to particular states, or to any particular phone number across an entire list.

In the Massachusetts challenge, the screenshot below shows an example of a PDAS setting to meet the 2 attempts per week Massachusetts restriction. Phone numbers are attempted 2 times within 7 sliding days, and then the phone number is prevented from dialing until the 7 day window has passed.

Benefits of a “Sliding” Calendar – Set it and Forget It!

Another key benefit of PDAS is a capability called “Sliding Windows”. In the Massachusetts example, this feature allows the clock to automatically begin the countdown to a 7 day period based on the first contact attempt. In comparison to the “Dial Only Days”, PDAS automatically allows you to dial on any day as long as it is in accordance with the pre-configured dialing window and limitations – eliminating the need for limited dialing days, manual calendars, and all the logistics needed to support it.

Preparing for 2017…..

Whether or not the CFPB’s proposal to “overhaul the debt collection market” will come to fruition over the next 24 months, agencies who have been able to leverage technology to solve for contact attempt requirements similar to those in Massachusetts will be better poised to address future challenges, whether it be regulatory or new contact channels.

For example, LiveVox’s cloud delivery model is rapidly extending PDAS’ controls to other contact channels including email, SMS, and print mail. PDAS is scheduled to include email as soon as the first quarter of 2017.

If you would like to learn more about PDAS, click here to speak with one of our operation consultants.

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