Collector - October 2017 - 22
all stages of your relationship-but especially
when you are onboarding new clients.
"More creditors are becoming amenable
to that because it impacts their liquidity
rate and the ability to collect on accounts,"
In fact, Womack noted that some
agencies are even offering contract language
consulting to prospective clients as part of
their sales efforts.
"We're seeing some agencies now
reaching out and being proactive in
coaching creditors through what they
need regarding obtaining, storing and
transferring that consent," he said. "It
takes time to make those changes-there
is a certain cycle to go back to those
agreements to add that language."
Offering contract consulting services
to prospective clients can help drive up
collection rates and, if they wind up
being a business partner, shorten the
onboarding process by buttoning up
contract language early on.
IS THERE VALUE IN VOICEMAIL?
Courts have delivered mixed messages
on the issue of voicemail message
content over the years, and there is not
a failsafe script agencies can follow
to leave a voicemail for a consumer.
Like many things in our industry,
the choice to use specific voicemail
message templates, such as those
suggested in the Zortmann or Foti
cases, is a business decision that each
agency must make for itself. Federal
and state laws will play a huge role
in how you develop your voicemail
script and delivery process.
Of course, if your agency does
leave voicemails for consumers
you need to have strict guidelines
in place governing their delivery.
This requires you to answer tough
questions which depend on your
specific business and risk tolerance.
For instance, will you leave a message
on a consumer's personal voicemail at
his job? Will the voicemail messages
be delivered by a live collector or
are there instances when you will use a
Debt collection agencies are also looking
at recent advances in voicemail delivery
mechanisms. Some agencies have started
using message drop services, also known as
ringless voicemail, which deliver a message
to a consumer's cell phone without actually
calling the phone.
"People can get their message or see the
number associated with the voicemail and,
with the right delivery metrics, you can
help drive inbound traffic," Harris said.
Agencies that use these systems often
report seeing a lift in inbound traffic when
call-drop campaigns are launched, so much
so that it becomes critical to coordinate the
drops with your staffing levels to reduce
hold times and abandonment rates.
The challenge with this type of service
is that it's still not clear if direct-drop
messages are considered a call under
the TCPA. In 2014, a ringless voicemail
provider, VoApps, asked the FCC to
clarify that ringless voicemail is exempt
from the TCPA but didn't receive a ruling.
When another provider, All About the
Message, petitioned the FCC in March
2017 on the same issue, consumer groups'
strong opposition prompted the company
to withdraw its petition before the FCC
could rule on it.
"On one level that clarity would be
good for all of us and I think [ringless
voicemail] could be a good tool," Harris
said. "I think the downside, if I could
polish up the crystal ball, is that if this did
get the green light, very quickly you'd see
people's inboxes inundated and they would
no longer respond to [voicemails]. So I
think when tools are unique and new they
can be much more effective, but once they
become commonplace and well used, the
people you are trying to reach become a
bit numb to them."
Womack said overall he's seeing the
use of voicemail decline in the collection
"People are either not leaving as many
or not finding much value in them as far as
callbacks," he noted.