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September 23rd, 2021

Four Steps to Placing Efficient Outbound Calls Under the CFPB’s Regulation F

The Consumer Financial Protection Bureau’s (CFPB) Regulation F goes into enforcement on November 30, 2021.[1] Under Regulation F, collectors may make only seven outbound calls in a rolling seven-day period—the so-called “seven-in-seven” rule. A collector that makes four call attempts to a consumer on a Wednesday will have to wait until the next Wednesday before four more call attempts become available.

Compared with the approaching “era” of Regulation F, subject outbound call centers used to be relatively free to attempt contact with individual consumers as many times as desired. A single contact attempt had little value because one missed attempt could be followed by another just a few hours later.

Highly efficient operations helped to compensate for legacy challenges that have depressed right-party-contact (RPC) rates for years: carriers mistakenly blocking and spam-mislabeling collectors’ outbound calls, calls displaying incorrectly on caller ID, consumer data changing regularly, and collectors reaching out to consumers without knowing when or how best to do so. Once tolerable costs of doing business, the seven-in-seven rule escalates these challenges into significant threats against business solvency.

The simplest solution to the seven-in-seven rule—making one call attempt per day—mitigates compliance risk but is not an effective communications or revenue-recovery strategy. A one-call-per-day approach delays consumer contact, possibly for weeks. While slower collectors wait to make contact, innovative collectors may reach the same consumer and arrange a payment strategy for another loan first. Collectors that fail to adapt their outbound communications strategy before Regulation F goes into enforcement risk falling behind competitors, collapsing profit margins, provoking regulatory fines, and increasing exposure to lawsuits.

How collectors’ outbound calls reach consumers more efficiently

To thrive under Regulation F, collectors must adjust from quantity-oriented operations to a focus on quality in every contact attempt. With just seven outbound calls per rolling seven-day period, each call must avoid errant call blocking and spam-mislabeling, display correctly on mobile devices, and go to the right person at the right phone number at the right time of day and day of week. The below four steps are key to an intelligent omnichannel strategy that complies with both the spirit and the word of Regulation F, improves RPC rates, and allows for faster contact than lagging competitors.

  1. Don’t Get Blocked. Each call attempt—including those that are errantly blocked or mislabeled as spam—counts under the seven-in-seven rule. Mitigating call blocking and spam-mislabeling ensures that no call attempt goes to waste due to protections against illegal robocalls.
  2. Brand Your Caller ID Experience. Due to advances in mobile caller ID, dialers can now represent themselves more faithfully by displaying information as part of the caller ID, such as the organization’s full name, logo, and reason for calling. Almost 90 percent of consumers say they are more likely to answer a call when they can be certain of the other party’s identity. Increasing consumer trust in calls drives up answer rates, which helps to compensate for the overall reduction in call volume.
  3. Reach Consumers the Right Way and Time. Knowing when each consumer is most likely to answer his or her phone facilitates a more strategic approach to the seven-in-seven rule. Certain days may qualify for multiple outbound calls at the right times, while other days may warrant only SMS/text messages or emails.
  4. Get Your Data Straight. Frequent CRM updates are a critical part of business processes, given the increased possibility that consumers will move[2] residences[3] or change phone information[4] due to financial hardship. Collections organizations that regularly integrate changes in consumer data position themselves to anticipate challenges, implement a successful omnichannel communication strategy, and increase RPC rates, while remaining compliant. More opportunities to secure promises to pay emerge when accounts deemed uncontactable become contactable via new insights into consumer information.

These insights into consumer information and communication behavior require constant investment and maintenance. Capturing and analyzing these data falls outside the scope of most collections organizations’ operating models, and yet this capability will become essential to thrive under Regulation F.

Placing effective outbound calls while complying with Regulation F

With enforcement of Regulation F on November 30, successful and compliant collections communications hinge on making the most of every contact attempt. Neustar TRUSTID Contact Center Solutions enable a quality-over-quantity approach.

  • Neustar Phone Behavior Intelligence helps collectors connect at the best time of day and day of week for each individual consumer.
  • Neustar SmartDial automates truly intelligent decisions on the best time and day to contact each consumer for collectors whose operations are constrained by legacy infrastructures, lack of resources, or limited IT support.
  • Neustar Trusted Call Solutions ensure outbound calls display with proper branding and are not improperly blocked or mislabeled as spam calls.
  • Neustar SmartTrace is a high-quality replacement to low-quality skip trace data, indicating the three best numbers to use, their respective phone types, and the best times to call each individual.

Forward-thinking collectors who invest in making every call, text, and email count position themselves to comply with Regulation F, uphold profit margins, and contact consumers faster than competitors. Neustar TRUSTID Contact Center Solutions supports this “quality-over-quantity" approach, enabling outreach over the right channel at the right time with the right presentation, dramatically improving the chances of consumers responding with the first outreach.

[1] AccountsRecovery.net, CFPB Announces Nov. 30 Effective Date For Regulation F

[2] CNN

[3] National Institutes of Health, Extremely low-income households, housing affordability and the Great Recession

[4] Barron’s, Wireless Carriers Aren’t the Recession-Proof Fortresses Phone Companies They Once Were, Analyst Says

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