Outbound IVRs come with potentially serious compliance risks, but that doesn’t mean your agency partners shouldn’t use them on your portfolio. When those compliance risks are managed, outbound IVRs are a great tool to increase right party contacts and liquidation without increasing the cost to collect. Here, Sara Woggerman from Research Assistant breaks down How You Can Manage the Compliance Risk with Outbound IVRs.
Using an outbound Interactive Voice Response (IVR) can be beneficial for collections, but it can pose real compliance risks if not deployed with strong controls.
What is an IVR, you ask? What is outbound IVR?
It is an automated system that many businesses use to interact with and gather information from consumers. Most of us are more familiar with inbound IVRs used for directing calls and taking payments when a consumer calls your organization. An outbound IVR is a contact solution used to proactively and systemically reach out to consumers. Though outbound IVRs have been around in the collection industry for quite a while, they’re typically used more by first-party agencies and creditors than by third-party collection agencies. This could be because of the increased regulatory risk found in the third-party setting.
Outbound IVRs use the contact information you have in your system to contact consumers using an automated system to request callbacks, payments, update location information, etc. Some of the technology groups that provide outbound IVR services can use their system to text and email consumers in addition to calling.
This sounds like a great tool, but... there are compliance risks to using it.
What are the compliance risks with using outbound IVR?
Outbound IVR attempts/contacts should be counted as attempts to communicate when calculating your call frequency. Consumer consent to receive an automated call using an artificial voice would either need to be passed down by the client or the agency would need to obtain direct consent before adding the consumer’s contact information into the outbound IVRs dialing/emailing platform to ensure TCPA compliance.
You also need to make sure your IVR isn't frustrating your customers. If your outbound IVR creates multiple steps that ultimately frustrate a consumer then your process may be creating additional issues rather than solving an operational problem. Testing the ease of use and monitoring your complaint trends will help you adjust your processes and workflow to avoid these risks.
What can you do about outbound IVR risk? Here are three best practices.
- Make opt-out options readily available to the consumer.
- Write policies and procedures that document the outbound IVR process and train your staff.
- And last but not least, audit the entire outbound IVR process on a regular basis.
Technology is an important part of collecting effectively and efficiently, but only if you do your vendor due diligence, document the process, train, and audit. Even machines make mistakes from time to time.
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