Collector - March 2021 - 16

hesitant to jump in without guidance saying
what they can and can't do. "
Fortunately, the CFPB rule, published
on Oct. 30, 2020, finally provides such
guidance and clarity for collectors
wanting to communicate with consumers
via text message.
Significant CFPB provisions regarding
collection agency text messaging include:
* Collectors may communicate with
consumers via text message if they have
express or implied consent and have
taken specific steps to ensure telephone
numbers used for texting remain
assigned to the consumers.
* Collectors must provide a clear,
conspicuous statement describing a
simple, reasonable opt-out method.
* The FDCPA's provisions prohibiting
communication at inconvenient times
or places applies not only to phone calls
but also to email and text messages.
* Collectors should analyze their
collective communications to
consumers via all channels-telephone,
email and text message-to ensure such
combined contact does not constitute
harassment, oppression or abuse.

There's little question that consumers
increasingly prefer communication via
text message over telephone, and the
new rule provides much-needed clarity
about how agencies can safely text.
The collection industry's adoption of
messaging protocols is poised to increase
as the rule's effective date of Nov. 30,
2021, approaches.
" I think 2021 will be the year agencies get
the technology, adapt it and have it ready,
and 2022 will be the year they really dive in
and start using it, " Beebe said.
Capital Collection Management (CCM)
has used text messaging for its commercial
accounts since 2013 and is preparing to
implement it for consumer debt as well.
" We want to be able to communicate
with consumers using their channel
of preference, " said CCM CEO Jacob
Corlyon. " Because consumers want
communication by text message, we
would use it regardless of the CFPB rule.
However, the CFPB adding clarity and
giving definition around the practice
definitely helps. "
CCM is taking steps to launch its
consumer text messaging program in

More Texting, Less Talking
According to a December 2019 survey of 1,000
consumers by texting platform Avochato:

16

75%

70%

63%

More than 75% of
respondents don't
answer phone calls
from anonymous
numbers.

Nearly 70% would
prefer an unfamiliar
company to contact
them via text rather
than a phone call.

Almost two-thirdsĀ (63%)
of respondents would
switch to a company that
offered text messaging
as a communication
channel.

2021. This includes shoring up consent
management policies and procedures
and educating clients about necessary
documentation and consent language.
" If a consumer on the frontside
of a transaction prefers to use SMS,
there's no reason why they shouldn't
be able to continue using it as their
preferred contact channel throughout
the relationship, " Corlyon said. " It's
important for creditors to make sure their
agencies are using similar communication
technology channels they use on
the frontside to keep that customer
engagement piece consistent. "
TrueAccord communicates with
consumers primarily by email but also
uses text messages for some outreach,
such as sending payment reminders, NSF
notifications and late-lifecycle engagement
attempts when other contact methods
have failed.
" Text messaging is a growing segment,
and we'll likely see that expand exponentially
in 2021, " said TrueAccord General Counsel
and Chief Compliance Officer Tim Collins.
" There's a huge pent-up demand for text
messaging by consumers. A lot of agencies
don't realize that consumers are already
texting their 800 numbers, but they're not set
up to receive those messages. "
Collins believes agencies that will be
most successful in the future are those
that can effectively communicate based on
consumer preference, whether it's email,
text messaging, social media apps or
another new method that becomes popular
in the future. Whatever channel is used,
communication should be as close to realtime as possible and truly interactive-not
just one-direction push notifications.
" Most agencies using text messaging
today are using it only in one direction, "
Collins said. " They send out a message but
want it to drive an inbound phone call. It
needs to be two-way. You wouldn't reach
out by phone if the person on the other end
couldn't immediately respond because that
would be extremely frustrating. Contacting
someone by text but not giving them the
opportunity to respond by text is the same. "

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Collector - March 2021

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