Response to the FCC Notice of Inquiry (NOI)

By on July 31st, 2017 in Compliance, Debt Collection, Industry Insights

The FCC recently released a Notice Of Inquiry (NOI) on the topic of on-call authentication, and the debt collection industry is again up in arms about its past, rather than embracing its future. Collectors are having a hard time authenticating consumers’ identity on phone calls, and that leads to a lower number of productive conversations. In a detailed article on InsideARM, Stephanie Eidelman correctly states that “While [the proposal] is not aimed specifically at debt collection, the problem is significant in the industry. The next trick would be to assist in helping the consumer authenticate their identity to a legitimate collector, in a way that eliminates the need to share personal information.” Dear collectors, there are wonderful authentication solutions available to you. Put down that headset, turn off your dialer, and turn your attention to the online world.

Consumer preference is changing. 97% of business calls go unanswered, according to Neustar. Phone calls are real-time interactions, imposing on the consumer’s time and attention. Once consumers pick up, they start from deep suspicion towards the person on the other side, who now has to earn their trust while asking for personal information. It’s a stressful situation, especially for someone paid a commission for collected dollars. Often this devolves into a heated exchange between a stressed consumer and an equally stressed collector. Calls aren’t only bad for reaching consumers; they are bad for engaging them in a meaningful exchange, too.

Emails and digital communication channels provide a superior customer experience. Emails and social media apps are password protected, simplifying the authentication process. If you require added security, many established companies offer real time authentication solutions that keep the consumer engaged with your system. It is easy to quantify and improve the experience to keep consumers engaged, reviewing their options, until they find one that fits. Consumers can choose to engage in times that work for them, rather than times when collectors are available to take their call. As a result, using digital channels significantly cannibalizes the phone channel: on average, TrueAccord makes 5 call attempts to each account over a 90 day placement period, compared with up to 6-10 attempts per day in call center based operations, and still collects better with lower complaint rates.

Calls pose multiple challenges – from operational ones to legal ones. They are costly and complicated. The FCC’s ATDS ruling is disastrous and further limits the efficacy of phone calls. Yet collectors choose to focus on fighting phone-related regulation instead of finding new ways to communicate with consumers. It is starting to look as though some prefer a contact method that consumers think of as harassing and intrusive, because moving to digital communications is simply outside of their comfort zone.

Leave a Reply

Your email address will not be published. Required fields are marked *