Archives for May 2020

Following in step with the extensions of its governor’s peacetime emergency declaration, Minnesota’s Commerce Department has yet again extended its allowance for debt collectors to work from home without branch licensing for the home locations. This is the second extension of the work-from-home guidance, which was originally issued on March 13 and extended for the first time on April 24. 

Like the initial guidance and first extension, the most recent extension—issued on Friday, May 15—reiterates the four criteria required in order to receive the benefit of the Department’s decision to take no action against agencies who temporarily allow their collectors to work from home. The criteria are:

1. The activity is conducted from the home location of an individual working on behalf of a Minnesota licensee;
2. The individual is working from home due to a reason relating to the COVID-19 outbreak and has informed the licensee of such reason.
3. None of the activity will be conducted in person with members of the public from the home location; and
4. The licensee shall, at all times, exercise supervision of the activity being performed at the home office and ensure that appropriate safeguards and controls are in place to protect consumer information and data.

The notice states:

The Commissioner recognizes that because of the concern surrounding the COVID‐19 outbreak, and in light of the Governor’s Executive Orders, individual collectors should be working from home temporarily to protect themselves and others, even though their home location is not currently licensed as a branch office.   

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Editor’s note: This article is provided through a partnership between insideARM and Squire Patton Boggs LLP, which provides a steady stream of timely, insightful and entertaining takes on TCPAWorld.com of the ever-evolving, never-a-dull-moment Telephone Consumer Protection Act. Squire Patton Boggs LLP—and all insideARM articles—are protected by copyright. All rights are reserved.

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As noted earlier, a 1,815-page House bill has just been introduced that affords $3 trillion in relief to consumers and businesses impacted by COVID 19.  The bill (official title: the Health and Economic Recovery Omnibus Emergency Solutions Act, or “HEROES Act”) addresses numerous topics, but I’d like to focus on one: amendments to the Fair Credit Reporting Act (“FCRA”) designed to prevent reporting of adverse information arising out of a national emergency.

However well-intentioned these provisions may be, they work an extreme—some might say unworkable and crazy— shift to the credit reporting landscape. If implemented, these changes would have significant negative impact on the financial services industry and consumers’ ability to get credit at rates reflecting their true repayment risk.

The House votes on and passed the Act on Friday but—unsurprisingly given the bill’s drawbacks— the odds of it passing the Senate and being signed by the President in its current form lie somewhere between very unlikely and a snowball’s chance in Hell.

Calling out a handful of the troublesome amendments to the FCRA proposed by the HEROES Act:

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All Adverse Information Arising from “Major Disaster” Must Be Excluded from Consumer Reports

Under the HEROES Act, consumer reporting agencies (“CRAs”) are prohibited from including “an adverse item of information” (other than a felony conviction) that was the result of “any action or inaction that occurred” during a period declared to be a “major disaster” by the President. There is a similar prohibition on furnishers furnishing such adverse information to CRAs. Think about that. But when is an adverse fact “the result of” an action or inaction that occurred during an emergency?  Some cases are easy – I’ve been in the hospital for two months with COVID-19, couldn’t work and so missed payments on my credit cards and mortgage. Fine. But if I’m a CRA and two years from now I want to include a bankruptcy in a consumer report, how could I possibly know if there was some action or inaction that took place during the pandemic such that the bankruptcy could be said to have “resulted” from such action or inaction? It’s an impossible standard.

A Catalog of Consumer Woe? HEROES Would Create CFPB Website to Track Consumers’ Economic Hardships

The HEROES Act requires the Consumer Financial Production Bureau (“CFPB”) to establish a website where consumers can report “economic hardship” as a result of a major disaster, including the current COVID-19 pandemic. It does not state that specified events resulting from such hardship (liens, bankruptcies, missed loan payments, etc.) are to be reported or otherwise elaborate on what constitutes an “economic hardship” for purposes of this website. It does, however, require the three credit bureaus and CRAs that qualify as “nationwide specialty consumer reporting agencies” to check this CFPB website weekly and delete from their databases “adverse items of information as soon as practicable after information that is reported appears in the database.” But how will a CRA know what to delete if consumers are not required to be specific about what events are a product of their “economic hardship”?  Oh, and the HEROES Act prohibits the CFPB from requiring any consumer to produce any documentation substantiating their claim of economic hardship.  Makes sense! Then there are the privacy implications of allowing/encouraging/requiring consumers to catalog their hardships in a centralized government database.

Guidance Regarding the Treatment of Missed Payments Is Insufficient

As noted above, the HEROES Act prohibits CRAs from reporting adverse items of information. That leads to some tricky situations. For instance, suppose a bank’s records show that in some months during the pandemic the consumer made payments on his outstanding credit card balance and in some months he did not. Under the HEROES Act, CRAs are not allowed to report the missed payments because they are “adverse items of information.”  So the bank will furnish CRAs with payment history for only the months in which he made payments.  How does the CRA then report that information without signaling that the consumer didn’t make the payment during the months not reported?

Debt Collection

Debt collectors routinely obtain consumer reports prior to attempting to collect a debt in order to confirm that debtors have not declared bankruptcy. If a consumer declares bankruptcy during a pandemic but CRAs can’t notify debt collectors of such bankruptcy, then debt collectors either run the risk of violating the law by attempting to collect debt from a bankrupt debtor or it has to stand up internal processes to check relevant sources to determine whether the debtor is bankrupt, adding significant cost to the collection effort.  This will be an unfair burden for debt collectors and increase the cost of credit for consumers.

Making credit more expensive

While the HEREOES Act raises many questions regarding reporting adverse information during an emergency, one thing is clear—the cost of credit is going up if the HEREOES Act becomes law. When lenders have more information about consumers, they can make finer distinctions among consumers about their relative default risks, which leads to better terms for many consumers.  This is the main driver behind the push towards “alternative credit data”:  it allows lenders to identify potential borrowers that are a good credit risk in a pool of consumers that don’t have much of a footprint in the traditional credit universe because, g., they lease an apartment, do not use credit cards or don’t have checking accounts.  To the extent regulatory prohibitions limit what data lenders are allowed to use in underwriting, the less lenders are able to offer loan terms that match a consumer’s true credit risk, making credit more expensive for everyone.  This would undoubtedly happen if the HEROES Act were to pass in its current form.

The HEROES Act is not workable in its current format as it pertains to the FCRA.  We will monitoring developments with the HEROES Act and blog about it as it develops.

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Want to track current FCRA court decisions and trends? The iA Case Law Tracker does that in less time than it takes to pour your morning cup of coffee.

This video is part of the iA Think Differently series. Written by members of the iA Innovation Council, the series showcases thought leadership in analytics, communications, payments, and compliance technology for the accounts receivable management industry.

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Today I’m joined by Scott Ferris and Rob Nadler, the CEO and VP Sales of Attunely. This relatively new company to the industry (they launched in early 2019) has brought the principles of the digital ad industry to the collections industry. What’s the cornerstone? Testing. You’ve got to be able to test scenarios and quickly deploy strategies based on data from that testing. 

[Editor’s note: If you are interested in topics like strategy, testing and scenario planning, you should not miss insideARM’s next conference, iA Strategy & Tech – a completely virtual event – July 21-23. It’s a masterclass in collections strategy.]

Transcript

The iA Innovation Council is a collaborative working group of product, tech, strategy, and operations thought leaders at the forefront of analytics, communications, payments, and compliance technology. Group members meet in person (and lately, virtually) several times each year to engage in substantive dialogue and whiteboard sessions with the creative thinkers behind the latest innovations for the industry, the regulators who audit and establish guardrails for new technology, and educators, entrepreneurs and innovators from outside the industry who inspire different thinking. 

2020 members include:

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Editor’s Note: This article originally appeared as an Alert on ClarkHill.com, and is republished here with permission.

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Since the beginning of the COVID-19 crisis, Democrats have been anxious to put forth their proposals and priorities for coronavirus relief. For the most part, those proposals were shut out of the CARES Act. On Tuesday, the Democrats unveiled their latest legislative proposal: The “Health and Economic Recovery Omnibus Emergency Solutions Act” or “HEROES Act.” The official summary of the bill calls it “transformative legislation to meet the challenges of the coronavirus pandemic, increase aid for state, local and tribal governments,” to extend unemployment insurance, and to provide direct aid to Americans. 

For the consumer financial services industry — particularly the credit reporting and debt collection sectors — the HEROES Act looks to amend  certain  consumer protection laws while at the same time applying a one-size fits all solution for every consumer regardless of circumstance. 

The details of the proposed legislation are as follows: 

Credit Reporting During Major Disasters

• Negative consumer credit reporting would be suspended during the COVID­19 pandemic, other declared major disasters, and for 120 days thereafter; 
• New credit scoring models that would lower existing consumer credit scores during the COVID­19 pandemic or during other major disaster periods would be banned; 
• Prohibit the reporting of medical debt arising out of COVID­19 treatments; and 
• Expand rights for consumers in order to delete negative tradelines. 

Restriction on the Collection of Consumer Debt During Major Disasters

• Create a temporary moratorium on consumer debt collection during this COVID­19 crisis and for 120 days thereafter (covered period); 
• Amending the Fair Debt Collection Practices Act (FDCPA) to include creditors under these provisions during the covered period;  
• Prohibited debt collection conduct would include legal action, enforcement of security interests, termination of utilities and threatening to do any of these activities. Non-legal activity would be permitted but will be limited by repayment and forbearance restrictions; and
• Determination that pre-dispute arbitration provisions are invalid and unenforceable during the covered period. 

Mandated Repayment and Forbearance 

• The FDCPA would be amended to require debt collectors to extend the time period for the repayment of a debt arising from credit within a defined repayment term by one payment period for each payment that a consumer missed plus one additional payment period; 

• For credit-card debt or open-ended credit, a consumer could repay the past due balance in a manner that does not exceed repayment options described in TILA; and 

• For all other debts, the consumer could pay in equal monthly installments, but only within a predefined time period depending on the amount owed, which can extend into a longer time period for repayment; 

• Upon request from the consumer, debt collectors must offer a forbearance program upon the request and attestation of financial hardship, directly or indirectly related to COVID-19, until the end of the covered periods. The consumer does not have to supply any documentation in support of the hardship; and 

• The Federal Reserve will establish a credit facility to make low-cost and long-term loans available to debt collectors to temporarily compensate them for the financial losses caused by the forbearance program. 

Government Payments for Private Student Loans 

• Extend existing CARES Act student loan payment and consumer protections (such as debt collection prohibitions) to private loan borrowers who are currently not covered by the CARES Act;
• Provide up to $10,000 in debt relief to be applied to a private student loan with the Treasury Department making monthly payments on behalf of the borrower up to $10,000 until September 2021. The borrower is not obligated to use that money to pay off any private student loan; 
• A debt collector could not pressure a borrower to elect to apply any amount received from the Treasury to any private student loan. Such conduct would be considered an unfair and deceptive act under Dodd-Frank as well as a violation of the FDCPA; and
• Private education loan holders must modify all existing loan contacts to provide for the same repayment plan and forgiveness programs that are available under the Federal Direct Loan Plan. 

Mortarium on Small Business Collections  

• Amend the FDCPA to include a temporary moratorium on small business debt collection during the same covered period; 
• Repayment and forbearance proposals applicable to consumer debtor would be applicable to small business debt; and 
• The Federal Reserve will establish a credit facility to make low-cost and long-term loans available to small business debt collectors to temporarily compensate them for the financial losses caused by the forbearance. 

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The financial services industry is sure to object to those proposals that attempt to re-write existing student loan contracts, eliminate arbitrations provisions that have been previously agreed to by consenting parties. The proposed amendments to the FDCPA will be a concern to creditors who never were covered under the statute.  Further the proposal to offer low-cost loans to the debt collection industry for “documented losses as the resulted of a forbearance” need to be carefully considered.  How is the loss documented? What happens if the consumer never pays or files bankruptcy? This is not a bailout rather a tenuous proposal which would require the debt collection industry to take on additional debt of their own, so that consumers can eliminate theirs.  

It’s a tale as old as time for those in the industry. A consumer files a bankruptcy petition without properly listing FDCPA claims, only to later file such bankruptcy-covered claims (often to their attorney’s financial benefit). Some relief from this scheme came in the Eastern District of New York (E.D.N.Y.) in the case Nunez v. Mercantile Adjustment Bureau, LLC, No. 19-CV-02962 (May 13, 2020). 

What Happened?

The case involves two different consumer plaintiffs who received an almost identical collection letter from defendant. After the letters were received, one of the consumers filed for bankruptcy and obtained a discharge of their debts. On the bankruptcy petition, the consumer scheduled only one FDCPA claim, alleging it valued at $1,000 for statutory damages. This claim was exempted. Despite this, the consumer and her husband went on to file five different FDCPA lawsuits that should have been scheduled. 

The Court’s Ruling

The court dismissed the FDCPA filed by the bankruptcy consumer for lack of standing. According to the court, the consumer lacks standing because the claims belong to the bankruptcy estate. The court states:

Plaintiff Khatun and her husband commenced multiple FDCPA suits against six distinct defendants, thereby frustrating a trustee who would have to “distinguish among multiple claims or multiple defendants.

This vague and misleading disclosure of scheduled assets plainly runs afoul of bankruptcy regulations.

The court also found that even if the consumer hypothetically had standing, the claims don’t have merit and thus would have been dismissed. These claims included allegations of overshadowing through the letters format and the inclusion of a sentence that states  “send payment and correspondence” to a specific address; as well as a claim that including multiple addresses confuses consumers as to where disputes should be sent, despite the fact that the letter clearly identifies only one of those addresses for correspondence. 

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insideARM Perspective

Let’s take a quick pause to state something worth noting—the consumer likely didn’t fully understand what was happening—bankruptcy filings and schedules are long and complicated documents. They were likely following the advice of their counsel.

It’s also worth noting that this particular consumer’s bankruptcy counsel is also listed as the consumer’s attorney of record in the FDCPA suit.

Often times, the bankruptcy schedule only lists $1,000 per claim, completely disregarding the fact that these claims are usually settled for much more than that and most of that settlement money goes into the attorney’s pocket, even if the settlement is reached in the earliest stage of litigation where there is no way that fees have amounted to that much. Debt collectors can’t do much—defending themselves against all of the many lawsuits and threats of suit that come their way is not feasible, as they are unlikely to be awarded their defense fees even if they succeed on the merits. 

And so the loop of this scheme keeps going and going.

However, there is hope. We are seeing a trend of court decisions where the judges call out plaintiffs’ counsel for wrenching the FDCPA from its original purpose—rather than protecting consumers, they’ve used it to bring “lawyer’s cases” to help lucratively line their own pockets. There are even circumstances where the courts are beginning to sanction plaintiffs’ counsel. 

Editor’s Note: The iA Case Law Tracker allows you to quickly pull all those decisions in a matter of seconds. 

Why are we seeing such an influx? Because debt collectors are choosing to defend more cases. Defending these hyper-technical, bogus “lawyer’s cases”—as opposed to settling on the outset—brings these cases to the judge’s attention and shows them just how twisted the situation has become. These are the same judges that, when appropriate, will issue sanctions against these attorneys.

Because of this, it’s no longer a no-lose game for plaintiffs’ counsel. 

Wilmington, Del. — Phillips & Cohen Associates, Ltd., the leading Estates management business servicing creditors in the US, Canada, UK, Ireland, Australia, New Zealand, Spain, Portugal and Germany is reporting a significant surge in online consumer activity via its proprietary Estate-Serve℠ platform during the COVID-19 pandemic. 

The business, which has been consistently recognized for its innovative technological solutions during its 23-year history, deployed its market leading Estate-Serve platform in 2013 and uses both traditional and extensive digital, self-service solutions to provide assistance to consumers and communities during the pandemic.  Over the past two months, the business has witnessed an incredible 60.3% increase in usage across its digital platforms and a staggering 320.7% increase in consumer-driven self-service payment volumes.

SVP Consumer Communication & Digital Strategy, Bob Bednar, commented “Phillips & Cohen Associates has always invested heavily in digital and technological solutions to support consumers and we are pleased to report a 40.5% increase in consumer visits and a 60.3% increase in meaningful online activity from those visits.  We continue to evolve and adapt our strategies to support consumers during this difficult time.”  

Nick Cherry, Chief Operating Officer added, “As a business, our focus is on providing consumers with the support and time they need to deal with the impact of the pandemic. A key element of that is maintaining service levels and making sure that we are available to support and communicate with individuals who have questions or want to resolve matters. The dramatic increase in digital activity shows that Estate managers are increasingly looking to use a channel choice that suits them, and we will continue to offer multiple, innovative options.”

Adam S. Cohen, Co-Chairman/CEO commented, “Our long history of implementing real-time speech analytics and extensive digital solutions mean that we can rapidly adjust strategies and focus on supporting consumers through both traditional and self-service channels.  We remain committed to providing consumers and communities with any support possible through this unprecedented time.” 

About Phillips & Cohen Associates, Ltd.

Phillips & Cohen Associates, Ltd. is a specialty receivable management company providing customized services to creditors in a variety of unique market segments.  Phillips & Cohen Associates, Ltd is domestically headquartered in Wilmington, DE, with additional offices in Colorado and Florida as well as international offices in the UK, Canada, Spain, Germany and Australia.  For more information about Phillips & Cohen Associates visit www.phillips-cohen.com. PCA provides Equal Employment Opportunity for all individuals regardless of race, color, religion, gender, age, national origin, disability, marital status, sexual orientation, veteran status, genetic information and any other basis protected by federal, state or local laws.

The California Consumer Privacy Act (CCPA), which became effective on January 1, 2020, substantially increased the privacy rights of California consumers.  The organization known as “Californians for Consumer Privacy” believes the CCPA does not go far enough.  This group is said to have obtained over 900,000 signatures on a petition in support of a new law which would be known as the California Privacy Rights Act (“CPRA”).  This proposed legislation is likely to be included on the California ballot this November. Although all of the specifics of the CPRA are not yet clear, it would include the following:

1. Additional rights regarding personal information;
2. Increased punishments regarding the assemblage and transaction of information of minors; and
3. Creation of an agency to enforce privacy rights.

The CPRA would also increase fines for violations of the CCPA pertaining to the private information of minors. Currently, the CCPA includes penalties of $2,500.00 per violation and up to $7,500.00 for intentional violations. The CRPA would raise these penalties to $7,500.00 per violation and $22,500.00 per intentional violation. This could result in massive penalties as violations are based upon fragments of personal information obtained, and businesses typically collect many such fragments including names, addresses, account information, phone numbers, and email addresses. 

The CPRA’s proposed enforcement agency would supplement the California Attorney General, which is charged with enforcing the CCPA. 

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Privacy Rights Are Here to Stay

Calls for the regulation of privacy rights are on the increase. The proposed CPRA demonstrates California consumers’ significant desire to protect their personal information from use by businesses in ways they do not intend.  Because the CCPA became effective on January 1, 2020, businesses should already be following their security policies and procedures regarding consumers’ personal information. Businesses not in compliance should take immediate steps to do so since the California Attorney General has pledged to meet its July 1, 2020 deadline to begin enforcement.  If the CPRA passes in November of this year, businesses that deal with personal information of California residents will have even more obligations.

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Editor’s Note: This article was originally published on Messer Strickler’s blog and is republished here with permission.

Editor’s note: This article is provided through a partnership between insideARM and Squire Patton Boggs LLP, which provides a steady stream of timely, insightful and entertaining takes on TCPAWorld.com of the ever-evolving, never-a-dull-moment Telephone Consumer Protection Act. Squire Patton Boggs LLP—and all insideARM articles—are protected by copyright. All rights are reserved.

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I love it when we have a chance to look deeper into the big TCPAWorld stories and share some fascinating tidbits with our readers.

One of the biggest stories of 2019 was the huge $267,000,000.00 verdict entered against collection company Rash Curtis & Associates in a certified TCPA class action. Although the judgment was not nearly the biggest of 2019—that “honor” belongs to ViSalus who was hit for nearly a $1BB earlier in 2019—the award was certainly eye-opening for the collection industry that had mostly avoided such huge-dollar TCPA verdicts in the past.

The story somehow became even bigger this year when the Court refused to reduce the award on constitutional grounds and awarded an eye-popping $89MM ($89,000,000.00) in attorney’s fees to the Plaintiff’s legal outfit, the always dangerous Bursor and Fisher.

Well, now we know a little bit more about the back story leading up to this train wreck on a dumpster fire. As gleaned from the decision in Perez v. Indian Harbor Ins. Co., No. 4:19-cv-07288-YGR, (N.D. Cal. May 11, 2020)(Perez-IH), it turns out that the Defendant (allegedly) could have walked away from the entire mess for under a million bucks at a mediation back in September 2017 but turned it down and decided to fight on. Ultimately it got creamed by a jury for roughly 300 times more than they (allegedly) could have settled for at mediation.

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Uh oh.

Interestingly, the Defendant may or may not have insurance for the TCPA claim at issue—the insurer denied coverage but Rash Curtis asserted a right to defense and indemnity and assigned its rights to a bad faith insurance claim to the Plaintiff. That set the stage for the filing of the complaint in Perez-IH which set forth a litany of purported missteps by the insurer in handling potential resolution of the case. The proverbial cherry on top—of course—was the story of the $875k mediation offer that was oh-so-imprudently left on the settlement table. The complaint also explains that “Rash Curtis walked out and made no settlement offer” at the mediation, a fact which—if true— speaks to an Odessyian level of hubris by the Defense.

The Court in Perez-IH ultimately determined that the events at the mediation are not properly pleaded in the complaint and ordered such allegations struck at the insurer’s insistence. Nonetheless, the case lives on—the Court determined the bad faith claim was live even though the underlying judgment against Rash Curtis is currently on appeal to the Ninth Circuit. In all likelihood, any chance that B&F will get paid for their work in the Perez trial hangs in the balance.

We’ll keep a close eye on this one.

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Looking for brief summaries of all industry-related court decisions? The iA Case Law Tracker does that in less time than it takes to pour your morning cup of coffee.

ATLANTA, Ga. — PossibleNOW, the leading provider of direct marketing compliance, enterprise consent and preference management solutions, today announced its partnership with Numeracle™, the pioneer of call blocking and labeling visibility in the calling ecosystem, to extend actionable measures to improve the accurate presentation of vetted and verified business calls.

As the only solution provider with a defined Know Your Customer (“KYC”) process to vet and verify the trust associated with an enterprise caller or call center solutions provider, Numeracle provides a single path to proactively identify legitimate entities and prevent the improper blocking of legal, wanted calls across multiple carriers and service providers. 

By establishing trust in the entity behind the call as well as any contact center partners facilitating compliant call delivery, Numeracle’s solution not only prevents the improper classification and blocking of calls today but prepares trusted callers for the next wave of call authentication through STIR/SHAKEN.

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“The issue is far more complex than monitoring ‘Suspected Spam’ or ‘Scam’ labels at the individual phone number level or employing a never-ending cycle of phone number rotation with diminishing returns,” said Rebekah Johnson, founder & CEO, Numeracle. “The remediation of phone number reputation begins by certifying trust in an organization’s identity and good standing through our NumeraCert KYC process. Organizations already taking advantage of PossibleNOW’s expertise in calling compliance are that much more ahead of the curve.”

“Improving a business’ contact rates, brand reputation, and customer engagement has become infinitely more complex due to the forward momentum of robocall blocking and labeling initiatives driven by the FCC, FTC, service providers, and consumer groups,” said Scott Frey, CEO, PossibleNOW. “In today’s uncertain economic environment, we know it’s more important than ever for trusted organizations to be able to maintain that positive interaction with their customers, patients, and members. We’re pleased to partner with Numeracle to ensure compliant, legal organizations may continue to leverage their communications channel of choice with as few interruptions as possible.” 

Since being founded in the year 2000, PossibleNOW has been focused on helping companies build trust with their customers through compliant and relevant communications. The partnership with Numeracle will help further this goal, through Numeracle’s mission to return trust and transparency to the voice channel. One of the first actions of our partnership is hosting a joint webinar about call blocking and labeling on Wednesday, May 20th, at 2pm EST – join us to find out how to improve your contact rates in the new era of STIR/SHAKEN. 

About PossibleNOW

PossibleNOW’s technology and services enable relevant, trusted, and compliant interactions between businesses and the people they serve. Its initial offering, DNCSolution, was tailored specifically to address the Do Not Contact databases and regulations such as TCPA, CAN-SPAM and CASL, allowing companies to adhere to customer do-not-contact preferences with peace of mind backed by a 100% compliance guarantee. Its enterprise consent and preference management platform, MyPreferences®, collects customer and prospect preferences, stores them safely and makes them available to any other system or application in the enterprise.

Additionally, PossibleNOW provides strategic services experts who define strategic roadmaps, plan technology deployments, and design consumer interfaces to position clients for success. PossibleNOW is purpose-built to help large, complex organizations gain control over communications, mitigate compliance risk and reduce marketing expenses while improving customer experience and loyalty. For more information about DNCSolution, visit https://www.possiblenow.com/do-not-call-compliance.

About Numeracle 

Numeracle is working with telecom carriers, call blocking and labeling analytics providers, device manufacturers, and industry leaders to deliver a path to visibility and control in the new calling ecosystem. Through the company’s technology vision and industry leadership, Numeracle is laying the foundation for returning trust and transparency to customer communications. To learn more about Numeracle’s call blocking and labeling solutions for call originators and call centers, visit www.numeracle.com.