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Lead Answer has contracted with the Federal and State agencies
to assure it is abiding by all the compliance procedures and protocol
required by law.
As one
of the mortgage marketing leaders providing reliable
data to several sectors of the financial industry, we utilize state,
federal, and internal or client-specific list management and scrubbing
capabilities, as well as a policy wizard to create and fulfill our
Do-Not-Call policy to consumers, and thorough documentation as well as
archiving and reporting tools.
As an
active and proficient marketing company we are
responsible for complying with state and federal laws and have
developed, enforced and documented our compliance efforts. As a
regulation set forth by the federal Do-Not-Call laws, we are required to
demonstrate that we perform the following as part of our routine
business practices:
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Establish and implement written procedures to comply with
Do-Not-Call laws. |
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Train our personnel in these procedures. |
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We maintain a company-specific Do-Not-Call list. |
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Scrub our calling lists against the national Do-Not-Call
registry on the frequency required by federal law. |
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Monitor and enforce compliance with our procedures. |
As a result of our
pro-active compliance measures, we seek a safe harbor defense to a
violation if the violation is the result of technical or human error.
We
have implemented a 2-step process for ensuring our compliance with these
laws. The 2 step process involves pre-dialing compliance as well as
pre-transfer verification.
Pre-dialing measures: All data is uploaded to our central database by
the call center staff for de-duping and scrubbing procedures prior to
dialing. Our automated system submits the data to DNC scrubbing software
which ensures all numbers are scrubbed against the appropriate Federal,
State and Internal DNC lists.
Our
systems maintain the strictest of compliance procedures including
tracking when numbers were checked and provides reports validating
scrubbing compliance.
Pre-Transfer measures: As the telemarketing agent inputs the prospect's
information in our website, we re-submit the phone number field through
the DNC scrubbing software to ensure that the prospect is absolutely not
on the DNC.
This
process also allows our customers to provide their own "internal" do not
call list, so that we can remove any customers that have requested not
to be called.
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Our
DNC Policy Statement |

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Consumers may request, by telephone or in writing, that our
company stop calling them and place their name on a "Do Not
Call" list. Although we may ask for your name, address and
telephone number, we will accept your request even if you only
provide your telephone number. You have a right to have calls
stopped and to be put on our "Do Not Call" list even if you are
still a customer. |

When we receive
your request, your telephone number is added to our "Do Not
Call" list within 5 business days. In some cases it may take up
to 10 business days for your telephone number to be removed from
other company wide calling lists. Your request will stay on our
list for at least 5 years. If you move, change your telephone
number, or add an additional telephone number, you must provide
us with the new telephone number in order for us to prevent
calls to that number. We will not share the information you
provide with anyone except affiliated companies or subsidiaries
without your prior written permission.
We may perform
telemarketing services for other companies. In
this case, we will also forward our updated "Do Not Call"
list(s) to these companies on a periodic basis, unless the
client requests otherwise or refuses to accept these updates
from us.
All employees that
engage in outbound telephone marketing are trained in this
policy and made aware of these procedures before they are
allowed to place calls to consumers. Managers, supervisors, or
trainers review the policy with these employees monthly.
If the consumer
notifies us that they have received a telephone call from us
after they have already requested to be placed on our "Do Not
Call" list, we will apologize for the intrusion and have a
manager or supervisor investigate. The manager or supervisor
will also personally confirm that the telephone number is on the
"Do Not Call" list. Upon request, we will mail the consumer a
confirmation that their telephone number is on the list.
The Federal Trade
Commission offers a free service to consumers that allows them
to place their residential phone number on a National Do Not
Call Registry. This service will reduce the number of
telemarketing calls received. Consumers may add their
residential phone number to the list either by calling
888-382-1222 or through the Internet at www.donotcall.gov. It
may take several weeks before you notice a reduction in calls.
The methods and
procedures in this "Do Not Call" policy are reviewed by
Compliance Managers annually. |