Collector - October 2017 - 23
THE NUANCES OF CALLER ID
Caller ID has played a big role in the debt
collection process, silently working to boost
inbound traffic. Federal and state laws
impose multiple restrictions on how debt
collectors handle caller ID, but there are
still plenty of unknowns.
"The clients that we talk with are trending
toward not leaving voicemail messages
and just relying on caller ID [to generate
inbound calls]," Womack said. "Those that
are doing that generally report no decrease
in their callback rate. They have the same
number of people calling them back as when
they left messages. I think it's often seen as
safer to not leave a voicemail message."
A growing number of debt collection
agencies are using local number projection
to help connect with consumers, and Harris
said his clients have reported the practice
yields a pretty high uplift in connections.
Businesses buy local phone numbers in
certain areas, and use those numbers to call
consumers in the area. It's arguably not the
same as spoofing, which is when people use
caller ID settings to display information
contrary to the caller's true origination.
The FCC's recent Notice of Proposed
Rulemaking and Notice of Inquiry put a
spotlight on caller ID spoofing, noting that
it does not believe there is any legitimate,
lawful purpose for intentionally spoofing a
number that cannot be called back.
That's the key: if consumers call the
number displayed on the caller ID, they
should be able to connect to an agency
representative. This practice not only helps
keep your agency in compliance, but also
has clear operational benefits. By using
a dedicated caller ID callback number,
collectors will know where the return calls
are coming from and can speak to the
consumer accordingly, plus you'll be able
to better track the effectiveness of your
Caller ID projection is governed by the
FDCPA and the FCC's Truth in Caller ID
Act, as well as state laws. Womack said he
hasn't seen anything come up that would
flag local call projection as being negative or
deceptive, so long as it is done correctly.
"You own [the number]," he pointed out.
"If someone dials that phone number back,
it will route to you, and you have a legitimate
business reason for the call. There are bad
actors spoofing caller IDs, robodialing and
pretending to be someone they are not on
the call, and so we certainly understand all
the focus on robodialing-for example, the
Robocall Strike Force-but that's certainly
not something any of the agencies we speak
with are doing," Womack said.
The FCC's latest updated Robocall Strike
Force Report focuses, in part, on caller ID
authentication through a proposed framework
called SHAKEN, which Harris describes as
"a bad acronym that involves tokenization"
to verify caller ID through an end-to-end
ownership of a call through the network.
"They are in the testing and validation
prototyping stage-there's a lot of heavy
lifting to come with this," Harris said. "But
this is the piece that, if it gets legs and moves
forward, I think could make our lives both as
consumers and collection agency owners a
lot better because the legitimate dialing we're
doing would make it through the network."
THIS TIME, IT'S PERSONAL
With all the telephony advances we're
seeing today, it can be hard to know which
are worth your time and money to pursue.
The answer lies in the unique characteristics
of your business.
There's not a one-size-fits-all plan
when evaluating potential changes to
your business's telephony practices.
What you do depends on your business,
collection markets, client agreements, and
understanding of state and federal rules and
regulations-not to mention a robust costbenefit analysis for every potential change.
"There is a lot of data out there and lots of
options for your business to try to increase
your contact rates," Womack said. "But in the
end, it's really a matter of what works best
for you in your space, so mining your own
data is key to finding a successful dialing
Anne Rosso May is editor of Collector
Consumer VoIP lines are
but present risks. Consider
flagging and/or scrubbing
them from your system to
be called manually until you
can get consumer consent
to be put on the dialer.
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
Dedicated caller ID
help collectors see where
the inbound calls are
coming from, plus you'll
be able to better track
the effectiveness of your