Archives for June 2021

Show Notes:

Kevin Kelly, leader of Clark Hill’s Government and Regulatory Affairs Group stops by Credit Eco to Go to discuss the changes in Washington and what financial services entities need to do to prepare for the days ahead. Kevin tells us that the priorities for the Biden Administration will be focusing, among other things, on the economic crisis and passing COVID relief in the form of direct stimulus as well as housing and rental assistance. However, the financial services executive branch agencies will be bringing a fundamentally different approach, focusing more on a populist agenda. With support from Sherrod Brown, who now will Chair the Senate Banking Committee, and Maxine Waters retaining her status as Chairwoman of the House Financial Services Committee, access to credit for underserved people and ensuring fairness and equity in the financial system will drive their agendas. Look for policies that will reflect “recovery for all” and initiatives that ensure the financial services industry is working for everyone.

DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

For over 10 years, Base Commerce has provided collections merchants secure and reliable solutions to accept payments. While a debt collector must have considerable empathy and persuasive skills, the right payment technology can play a significant role in making the process faster, more accurate and deliver better outcomes.

Improving Payment Acceptance

If you own a debt collection business, your success strategy should begin with the customer. Making it easy for your clients to pay is the simplest and most effective way to increase revenue streams and reduce time to payment.

When a debtor has an easier time making payments, they’re more willing to work out a payment plan. Base Commerce can help you improve payment acceptance in the following ways:

1. Payment Types: Let your customers choose how they want to pay. Accept credit and debit cards, HSA cards, ACH payments, mobile wallets and more!
2. Flexibility: Don’t rely on agents answering the phone. Make it easy and convenient for your clients to pay whenever they choose. Base Commerce offers integrated payment solutions for card-present and card-not-present payment acceptance methods. With a virtual terminal or online payment gateway, you can accept payments 24/7/365.
3. Uptime: Ensure maximum uptime with minimal interruptions. When someone is ready to make a payment there should be no hiccups.
4. Compliance & Security: Collections merchants operate in one of the most highly scrutinized and regulated industries in the U.S. Achieving and maintaining adherence to the myriad of processing guidelines (FDCPA, TCPA, FCRA, HIPAA, PCI, CFPB, etc.) is a labor-intensive but crucial job for agencies. Base Commerce solutions can help you ensure compliance to protect your business.

Reducing the Cost of Accepting Payments

Our No-Cost-to-Biller™ solution is an integrated model of processing which allows collection agencies to process credit cards, debit cards, HSA/Flex cards and ACH transactions for FREE. To ensure compliance, this solution was developed in collaboration with FDCPA expert and industry leaders in compliance.

How It Works

It’s simple. Whether the transaction is processed through an agent, web portal, or IVR, a service fee is assessed for each transaction. For example, if your consumer pays $100 with a credit card, the principle amount of $100 is processed by your agency and the service fee is processed by Base. The service fee is charged as a separate transaction and subsidizes your agency’s processing cost, which means your payment processing is FREE.

Transaction Fee Structure

Take advantage of the No-Cost-to-Biller™ fee model and save money on transaction processing fees while remaining compliant with regulatory agencies. Our hybrid fee structure can be customized to fit your clients needs. Standard fees can be waived or passed along; you decide!

The following is designed to show how Base structures the fee model with a flexible, hybrid approach, accomplished by issuing three separate MID accounts to the Merchant.

Fully Compliant

In addition to the processing guidelines, there are also card brand rules that have to be followed to ensure payments made using Visa, Mastercard, Discover, Amex, HSA and other cards continue without interruption.

Base Commerce recognizes the importance of staying in compliance with all these requirements to help mitigate risk, but more importantly to ensure that agencies can process payments promptly and continually.

Our No-Cost-to-Biller™ solution is designed to address the four primary compliance pillars:

• Card brand rules
• FDCPA
• CFBP
• State law

Partnering with Base is the best way for an agency to safeguard against FDCPA liability when assessing a service fee. We have strong banking relationships that encourage our processing model and strongly support our secure solution. Not sure if your consumer’s state supports the NCTB model? No worries—our system can programmatically determine if the consumer resides in a fee-restricted state. If so, standard processing will be processed in that transaction.

Getting Started

Are you ready to improve payment acceptance and reduce the cost of processing payments?
Base Commerce can help!

If you’d like more information on our No-Cost-to-Biller™ solution, click on the link below:
https://e.nuvei.com/basecommerce-receivables-management-article/

If you would like a free consultation, please contact:

Matt Nuyen
Sr. Enterprise Sales Manager
(833) 616-6669
matthew.nuyen@basecommerce.com

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MINNEAPOLIS, Minn. — DCM Services, LLC (DCMS) the industry leader in estate and specialty account recovery solutions, announces the addition of Elva (Betz) Krantz, SHRM-SCP to its senior leadership team. Elva will lead the DCMS Human Resources team as Vice President, Human Resources.

Krantz is a results-focused Human Resources leader with over 15 years of experience as an HR professional. “DCMS ran an extensive search for this position”, said Tim Bauer, DCMS’ Chief Executive Officer. “In the post COVID-19 environment, we were looking for new thoughts and strategies to attract, train, and retain new employees.  Additionally, we were looking for someone with the knowledge and passion to lead our DEI initiatives. We are thrilled to have found Elva. We believe she will be a great addition to the team.”

Krantz commented on her hiring and her new role, “DCMS has a great leadership team, and I am honored to become part of it. I am excited for the opportunity to contribute to the success of the organization, and I am looking forward to rolling up my sleeves and diving in.”

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In addition to her membership in the Society of Human Resource Management (SHRM) Krantz holds Bachelor of Arts degrees in Human Resource Management and Business Management from Bethel University.

About DCM Services
Minneapolis-based DCM Services is the industry leader in estate and specialty account resolution services, maximizing the value of client portfolios across financial services, healthcare, auto, retail, telecom, credit union, government and utilities industries through innovation and performance. Its recovery solutions offer a full range of services from proprietary web-based solutions to full outsourcing, maintaining an unmatched spectrum of innovative solutions that increase recoveries, protect brand value, and enhance survivor relationships – with respect and sensitivity. For more information on all DCM Services’ offerings, please visit www.dcmservices.com.

Join 1,500+ industry professionals in following DCM Services on LinkedIn →

Well this is a big one.

In the best analyzed post-Facebook ATDS decision to date, a Court in South Carolina has ruled the Aspect predictive dialer is not an ATDS because it lacks a random or sequential number generator. The decision is Timms v. Usaa Fed. Sav. Bank,  C/A No. 3:18-cv-01495-SAL, 2021 U.S. Dist. LEXIS 108083 (D.S.C.  June 9, 2021) and–if defendants are lucky–the decision will form the bedrock for predictive dialer jurisprudence moving forward.

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Most critically, the Court cabins off footnote 7 and interprets it as applicable only to systems that actually use a random and sequential number generator to select the sequence of numbers to be dialed–but not to every dialer that calls sequentially.

Also important- the Court found that the system lacked the capacity to randomly or sequentially generate numbers–crediting the declarations from the Defendant to that effect. Interestingly, the declaration did not appear to come from Aspect–meaning there  was no deep review of the system’s true capabilities–but the Court relied on the operation of the system in practice by the Defendant on the issue of capacity. That’s pretty interesting.

To get there, the Court relied on the Plaintiff’s own submissions in connection with the undisputed facts at issue. The Plaintiff’s statement noted that the dialer called “sequentially”–but not that it used a random or sequential number generator to determine the sequence of dialing. That was Plaintiff’s critical error in the court’s view.

Here’s the punchline:

There is no evidence that the Aspect UIP or Aspect AIC store numbers using a random or sequential number generator or produce numbers using a random or sequential number generator. Both systems “are capable of making telephone calls only to specific telephone numbers from dialing lists created and loaded by” Defendant. Deneen Decl. at ¶ 6. They “cannot store or produce telephone numbers using a random or sequential number generator.” Id. at ¶ 13. 

Yeah, that’s pretty good.

Again, however, caution is urged here. Keep in mind that the declaration here came from the Defendant, not the software provider. Had Plaintiff come forward with some contrary evidence regarding the capacity of the system to select numbers randomly or sequentially the result may have been different. And while the Court in one breath limits footnote 7 to “preproduced lists” that are “sequentially generated and stored,” in another it recognizes the application of footnote to dialers that use a random and sequential number generator to determine the sequence of numbers to be dialed.

We’ll obviously keep an eye on these cases as they develop.

The U.S. Court of Appeals for the Second Circuit has ruled that a debt collector did not violate the Fair Debt Collection Practices Act by sending the plaintiff a settlement offer that did not disclose that his balance could increase due to interest and fees. 

In Cortez v. Forster & Garbus, LLP, the debt collector sent a collection notice to the plaintiff offering various options for settling his account for less than the full balance owed if he made the payments indicated by the dates specified in the notice. The plaintiff alleged that the debt collector violated the FDCPA by failing to disclose that interest was continuing to accrue on his balance.

In its 2016 decision in Avila v. Riexinger & Associates, LLC, the Second Circuit held that a collection letter that states a debtor’s current balance but does not disclose whether interest and fees are accruing is misleading in violation of FDCPA Section 1692e.  However, the Second Circuit also provided two safe harbors from liability under Section 1692e for failing to make such a disclosure.  A debt collector would not be liable if the letter either (1) accurately informs the consumer that that the amount of the debt stated in the letter will increase over time, or (2) clearly states that the holder of the debt will accept payment in the amount set forth in the letter in full satisfaction of the debt if payment is made by the specified date.

In reversing the district court and directing it to enter summary judgment in favor of the debt collector, the Second Circuit disagreed with district court’s reasoning that a settlement offer could be misleading if it contained a payment deadline but did not disclose whether interest or fees would accrue if payment were tendered after the deadline.  According to the district court, the least sophisticated consumer could interpret such an offer to imply either that interest and/or fees would accrue after the deadline or that the balance would remain the same after the deadline.

However, in the Second Circuit’s view:

Section 1692e does not require that a collection notice anticipate every potential collateral consequence that could arise in connection with the payment of a debt.  Instead, the FDCPA merely requires that a collection notice, by its terms, not be susceptible of a reasonable but inaccurate interpretation.  Therefore, a settlement offer need not enumerate the consequences of failing to meet its deadline or rejecting it outright so long as it clearly and accurately informs a debtor that payment of a specified sum by a specified date will satisfy the debt. (citations omitted, emphasis included).

Applying these principles, the Second Circuit held that the debt collector’s notice did not violate Section 1692e because “even when viewed from the perspective of the least sophisticated consumer, the [collector’s] notice could only reasonably be read one way: as extending an offer to clear the outstanding debt upon payment of the specified amount(s) by the specified date(s).”  Since the only reasonable interpretation was accurate, there was no FDCPA violation.

Little did the Federal Communications Commissions (FCC) know that when they signed the First Order of the Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act in late 2019, a global pandemic would follow suit and affect the way the world would soon depend on the communications channel so heavily. With this dependency came an open window for bad actors in the ecosystem to take advantage of the opportunity to scam consumers. 

Mistrust in the industry has grown rapidly, with many legitimate and critical calls going unanswered. The FCC’s timing could not have been more perfect in presenting the mandates included in the TRACED Act to create a framework to identify authenticated callers and reduce the amount of fraudulent and spam phone calls in the caller ecosystem. The Act put forth a framework designed to authenticate the identity of callers to keep these scammers out, along with a deadline to ensure that the implementation was to be prioritized. 

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TRACED also set out to establish rules on caller ID authentication in non-IP networks, establish frameworks for exemptions from and extensions of the June 30, 2021 STIR/SHAKEN mandate deadline, impose obligations on intermediate providers, and create a new registration framework for all voice service providers. For an expanded summary of the proceedings background and inclusions, check out: Latest FCC Move Against Robocalls Would Increase Caller ID Authentication, Other Requirements from Wiley.

How STIR/SHAKEN Works

SHAKEN is a framework that is built on the idea of STIR protocol. It provides an end-to-end architecture for service providers to verify and attest who is originating the call so a terminating carrier can validate it, thus identifying the callers’ identity. 

When an originating provider knows the customer and can verify where the number originated, they can add a certificate to the SIP invite, therefore attesting the call. This acts as the telephone identity that gets attached to the SIP invite to be transported over the SIP network to the terminating service provider. When the terminating carrier receives the certificate, they verify the validity of the attached certificate, if it has been signed by the relevant key that has been attested, and then choose how to terminate that call. 

This process is what is known as the Base STIR/SHAKEN Standard that needs to be implemented by June 30th, 2021. 

The Enterprise Challenge

Indirect cases in this flow exist which result in an Attestation Gap, also known as the Enterprise Challenge. A key component of the STIR/SHAKEN certificate is the Attestation Level which can be ranked as A, B, or C. These ranks depend on the relationship between the originating provider and the customer as well as to the origination of the phone number. Visit our STIR/SHAKEN Knowledge Center to read more about Attestation Levels. How these ranks will be visually displayed to the customer has still not been determined, however, some attestation A calls can display a checkmark or [V], depending on the subscribers’ device, either on the incoming call screen or in the call log. 

A very real-life example of the Enterprise Challenge, or Attestation Gap, could occur when a contact center partner or BPO is making calls on behalf of multiple clients involving more than one party during the call path. The end clients being represented (enterprise brands) would not have a direct relationship with the voice service providers (VSPs) utilized by the BPO/contact center, which causes a situation where the VSP may not be able to validate the identity of the end brands, or the brands’ authorization to display the phone numbers being used. 

About the STIR/SHAKEN Deadline

The First Order of the TRACED Act was signed by the FCC in December of 2019 to outline the implementation of the STIR/SHAKEN authentication framework, mandating that originating and terminating voice service providers must implement the standards in the IP portions of their networks and take reasonable measures to implement the framework in the non-IP portions of their networks. This implementation is set to be done by the end of this month on June 30th, 2021. 

For a full review on the timeline of Robocall Initiatives which set these new expectations for voice service providers into motion, check out Wiley’s recap on the regulatory landscape. As mandated alongside the STIR/SHAKEN implementation deadline, “[voice] providers will be required to certify [in a] new database. For those providers that are subject to an extension of this deadline, they will need to have implemented a robocall mitigation program and to certify as such in the new database.” 

Preparing for the Deadline: Enterprise Callers

As an enterprise caller preparing for June 30th, 2021, the first step would be to get an assessment of how your service provider is preparing for the deadline. Whether your calls originate via BPO, CPaaS, UCaaS, or direct carrier, your providers can update you on the status of their implementation as well as how your relationship with them may affect the level of attestation your calls may end up receiving. 

Next, inquire how your provider’s compliance with the law is going to impact your current contract. Be aware beforehand of the contractual impact, such as an increase in cost or service-level agreement changes, that the implementation may have on your business.

Third, keep in mind that reputational analytics will continue to exist within the mobile and app ecosystem to determine if calls are unwanted or suspected scams, so call blocking and labeling will still be a relevant issue that you’ll need to address. STIR/SHAKEN does not replace the technologies used today to display calls as Spam of Potential Fraud, but may be used as an additional datapoint to increase the accuracy of reputational analytics. 

Preparing for the Deadline: Service Providers

In April 2021, the FCC’s Wireline Competition Bureau announced the opening of the Robocall Mitigation Database, including filing instructions and deadlines for communications providers. Pursuant to 47 CFR § 64.6305(b), all voice service providers must file certifications to the Robocall Mitigation Database providing detailed information regarding their implementation of the STIR/SHAKEN caller ID authentication framework and/or a robocall mitigation program.

“These mitigation programs are going to be tailored to a carrier’s particular services and their particular mix of customers. So it’s not really going to be a cookie cutter situation where the obligations are the same. What you need to do if you’re a small MVNO reseller is different than what you’re going to need to do when you’re a service provider to the call center industry and are enabling outbound calls that can be high volume calls.” – Kelley Drye Partner, Steve Augustino 

The Robocall Mitigation Database is accessible to the public, where an active listing of all voice service providers that have submitted sufficient filings can be reviewed, and detailed instructions for how to file can be obtained.

• View current list of providers who have completed filing
• Still need to file? Review the instructions here

As noted while viewing the Robocall Mitigation Database, if you believe there are errors with the content or function of the database, or if you require special assistance with submitting a filing, please email FCC staff at RobocallMitigationDatabase@FCC.gov.

Preparing Your Robocall Mitigation Plan: Service Providers

As Wiley notes in this article on Expectations for Voice Service Providers, the filing of a robocall mitigation plan “applies to all voice service providers – not only those granted an extension – who will be required to file robocall certifications with the FCC.” With a special thanks to our friends at Kelley Drye, we recommend taking a look at the following helpful resources for service providers to further dive into the requirements set forth by the FCC to file a robocall mitigation plan:

• Guidance for Implementing the STIR-SHAKEN Call Authentication and Robocall Mitigation Mandates in 2021: to help communications providers determine what their obligations are under the rules, including a review of requirements and exemptions.
• Robocall Mitigation Plan Checklist: review and understand the three required elements of a robocall mitigation program as defined by the FCC.
• Podcast: Robocall Mitigation Plans: understand when providers need to implement mitigation programs and what needs to be included. Review recommendations for customizing a program to fit a provider’s needs and how to build a program that is both effective and manageable. 

So What Happens on July 1?

One of the major concerns facing the communications industry is the fear that outbound calls will be automatically blocked starting on July 1, 2021 if service providers have not properly implemented the authentication standard by the mandated deadline. Within the TRACED Act, however, there is no specific language included that states unattested enterprise calls will be simply blocked. As denoted in TRACED Act, SEC. 4. Call Authentication, further rulemaking will be issued to ensure “calls originating from a provider of voice service in an area where the provider is subject to a delay of compliance with the time period described in subsection (b)(1) are not unreasonably blocked because the calls are not able to be authenticated.”

In an episode of Numeracle’s Tuesday Talks series, we asked Chris Wendt of the ATIS/SIP Forum IP-NNI Joint Task Force and the STI-GA Technical Committee to de-bunk STIR/SHAKEN misconceptions, such as “what’s going to happen to calls starting to July 1?” In his reply, Chris shares his perspective on how the timeline to deploy STIR/SHAKEN across the large and unique mix of service providers required to sign traffic across the network might impact the customer experience on the terminating side.

Looking to the Future

As service providers continue to implement STIR/SHAKEN, conversations will continue around  how to address the Attestation Gap for the enterprise, how to effectively monitor and address for discrepancies implementing STIR/SHAKEN cross-provider, how to educate mobile subscribers on what the new visual descriptors of authenticated calls (such as green checkmarks) mean, and more. All said, ever since the FCC unanimously agreed to increase caller ID authentication last year, STIR/SHAKEN is the foundational next step in restoring trust throughout the network and lays critical groundwork for further developments in a secure identity-based voice channel.

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About this Article

Endeavoring to shed light and bring truth on emerging topics in the communications industry, Numeracle’s CEO and Founder, Rebekah Johnson, alongside Numeracle’s Chief Product Officer, Anis Jaffer, have begun a biweekly live discussion series-turned-podcast, Tuesday Talks. Their first episode was aimed at debunking the STIR/SHAKEN deadline, explaining the qualifications for attestation levels, the Enterprise Challenge, and other complex scenarios.

To listen in on these and other full episodes of Tuesday Talks, visit   https://www.numeracle.com/tuesday-talks, or check out our STIR/SHAKEN Knowledge Center for additional information around the rollout of the STIR/SHAKEN call authentication framework. 

TREVOSE, Pa. — Ralph Liberio, President & Chief Executive Officer announced today that NCB Management Services, a national Debt Buyer and Accounts Receivable Management (ARM) organization has acquired Premier Forty Financial, LLC, headquartered in Rockwall, TX.  This acquisition will allow NCB to further expand their footprint in the Auto Financing vertical, which includes multiple operational capabilities from servicing to debt purchasing.  Transaction terms were not disclosed.

“As a respected and well-known turn-key debt buyer and full spectrum ARM Services provider, this acquisition has further strengthened our position and expanded our footprint in the auto lending marketplace,” Liberio said. “We are excited about the growth opportunities that will come from this transaction over time.”

Premier Forty Financial, LLC is now a wholly-owned subsidiary of NCB Management Services, Inc. and will continue to operate under its same entity name with Shannon Rodden, President of Premier Forty Financial reporting directly to NCB’s Chief Executive Officer at NCB Management Services, Inc.

Premier Forty Financial, LLC has a long history in the Auto Finance Industry, and possesses the intellectual knowledge, expertise and business relationships focused on the recovery of ancillary product balances.

“We are excited and look forward to leveraging the robust infrastructure, technology platform and Compliance Management System of NCB while delivering exemplary performance results to P40’s clients,” Rodden said.

NCB Management Services, Inc. delivers superior, professional performance on behalf of their clients by focusing on compliance, regulation, and having a team of people dedicated to providing clients with the highest level of support.

For more information about recent news regarding NCB Management Services, Inc. please contact info@ncbi.com, visit https://ncbi.com/news, or follow them on LinkedIn.

About NCB Management Services

NCB Management Services, Inc. was established in 1994 and is headquartered in Trevose, PA with satellite offices in Jacksonville, FL, Sioux Falls, SD, and Lincoln, NE.  NCB is a well-respected Debt Buyer of Unsecured Consumer Credit Products and an admired, well-recognized Accounts Receivable Management (ARM) industry leader.  By blending many years of ARM experience with the latest in new information systems and communication technology, NCB has developed a reputation as consistently being a valued business partner and performer in a wide variety of applications. Achieving maximum results and protecting our clients valued reputation are among our highest priorities.

About Premier Forty Financial

Premier Forty Financial, LLC, headquartered in Rockwall, TX employs a team of employees who have years of experience in the recovery of Ancillary Product Balances.  They have developed a reputation as an industry leader in this space. 

LOCKPORT, N.Y. —  Spire Recovery Solutions, a professional and nationally licensed full-service debt collection agency located in Lockport, New York, announces a $1500 donation to the Shriners Hospitals for Children. Shriners is a nationwide network of non-profit medical facilities that provides specialized pediatric care regardless of families’ ability to pay.

“In these difficult times, we all have the power to create positive change and make a meaningful difference. Whether we choose an organization that is helping the world or just the world of one person, every act of kindness creates an endless ripple. Spire Recovery Solutions is committed to doing our part to create a healthier tomorrow, one donation at a time,” says CEO Jacob Torriere. “We see the great service that Shriners Hospitals provides across the U.S. for children in need of specialized pediatric care. Our team hopes that this donation will be the catalyst for the ripple of positivity and health that these children will carry forth into their futures.”

For 99 years, Shriners Hospitals for Children has provided exceptional health care for children through high-quality, innovative research in a patient and family-centered environment. With 22 locations, telehealth sites, outreach programs, and community clinics, Shriners has treated more than 1.4 million children since its inception. Through research and new knowledge, they continually improve the therapeutic treatment, quality of care, and outcomes provided to patients and their families. They deliver advanced care and procedures for orthopaedic and neuromusculoskeletal conditions and injuries, burn care, spinal cord injuries, craniofacial and cleft lip/palates, sports injuries and fractures, and other complex health needs.

“Spire Recovery Solutions supports Shriners Hospitals for Children and their mission of improving the lives of children and families. We are an organization focused on helping not only our consumers but also our communities. We understand that we make a life by what we give and hope that by leading with action, others will feel inspired to give of their time or to make a donation to help their neighbors in need,” continues Mr. Torriere.

For more information about the Shriners Hospitals for Children, please visit shrinershospitalsforchildren.org. To learn more about Spire’s support of other charitable organizations including the Naked Warrior Project, Special Operations Warrior Foundation, Feedmore WNY, as well as other charitable actions, please visit Spire’s News page.

About Shriners Hospitals for Children

Shriners Hospitals for Children was founded on orthopedics in 1922. With a network of 22 non-profit medical facilities across North America, they specialize in acute and rehabilitative burn care, customized solutions for cleft lip and palate repair, and spinal cord injury repair and regeneration research. All Shriners’ services are provided in a family-centered environment regardless of the patients’ ability to pay.

About Spire Recovery Solutions

Spire Recovery Solutions, LLC was founded by U.S. Veterans Joseph Torriere and Jacob Torriere. Spire is located in Lockport, NY, is a professional, nationally licensed full-service debt collection agency that assists creditors in the recovery of outstanding balances while providing consumers with exceptional customer service. Their company’s customized processes and state-of-the-art technology provide transparency and compliance that clients and consumers trust and rely on while working together toward account resolution.

ST. GEORGE, UT — TCN, Inc., a global provider of a comprehensive cloud-based call center platform for enterprises, contact centers, BPOs, and collection agencies, today announced the launch of “Understanding STIR/SHAKEN,” an online guide that breaks down the most important rules and issues related to the new Secure Telephone Identity Revisited/Signature-based Handling of Asserted Information Using toKEN (STIR/SHAKEN) framework, which takes effect on June 30, 2021. It also addresses the additional FCC rules of the Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act for businesses that are unable to implement STIR/SHAKEN right away.

“Every day, Americans receive millions of fraudulent, unwanted phone calls, including calls with malicious intent that ‘spoof’ or falsify caller ID information,” said McKay Bird, chief marketing officer at TCN. “These spoofed calls are not just an annoyance — they represent billions of dollars lost to fraud, damage consumer confidence in voice networks and threaten public safety. STIR/SHAKEN is an important and needed step toward restoring the trust of Americans in their voice networks and giving them a greater degree of confidence that the caller ID information they receive on their phone is accurate.”

STIR/SHAKEN (Secure Telephone Identity Revisited/Signature-based Handling of Asserted Information Using toKEN) was introduced by the Federal Communications Commission (FCC) as a framework for preventing fraudulent and unwanted calls to consumers. It is an industry-standard caller ID authentication technology that allows voice service providers to verify that a call is in fact from the number displayed on Caller ID. STIR/SHAKEN assigns a certificate of authenticity to each call and digitally validates the handoff of calls carried over Internet Protocol (IP) networks. The FCC expects that widespread implementation of STIR/SHAKEN will reduce illegal spoofing, allow law enforcement to identify bad actors more easily and help service providers identify calls with illegally spoofed caller ID information before those calls reach their customers. The FCC requires service providers to adopt and deploy a STIR/SHAKEN solution by June 30, 2021.

“STIR/SHAKEN is about validating the caller’s identity between the caller and callee, the originating/terminating carriers and all the touchpoints in between,” said Bird. “For contact centers, call centers and BPOs, STIR/SHAKEN is an important tool for building trust that can further protect your organization from the possibility of being misidentified when contacting customers. It also allows voice service providers to provide helpful information to their customers about which calls to answer.”

TCN’s STIR/SHAKEN online resources for businesses include:

●      The Real Reasons for STIR/SHAKEN

●      Breaking Down STIR/SHAKEN

●      Why is STIR/SHAKEN So Important to My Call Center?

●      A Quick Look at the Entire Process

●      What Can STIR/SHAKEN Do and Not Do?

●      How STIR/SHAKEN Works

●      STIR/SHAKEN Technology: How It Will Impact Your Call Center

●      Q&A: STIR/SHAKEN

TCN has already implemented STIR/SHAKEN protocols with carriers. Its clients have the opportunity to take advantage of TCN’s full attestation protocols that can help verify business phone numbers while reducing compliance risk. For more information, go to: https://www.tcn.com/understanding-stir-shaken/.

About TCN, Inc.

TCN is a global provider of a comprehensive, cloud-based call center platform for enterprises, contact centers, business process outsourcing firms (BPOs) and collection agencies. Founded in 1999, TCN combines a deep understanding of the needs of call centers with a unique approach to pricing – no contracts, monthly minimums or maintenance fees – that supports rapid scaling and instant flexibility to changing business needs. TCN’s flagship platform for contact centers, TCN Operator, features a holistic set of easy-to-use, automated agent tools and advanced apps for omnichannel communications, workforce engagement, compliance & data management, integration & automation, intelligence, reporting & analytics and collaboration & accessibility. Its suite of compliance tools helps businesses meet the requirements of the Telephone Consumer Protection Act (TCPA) and other state and federal regulations, including new and updated debt collection rules issued by the Consumer Financial Protection Bureau. TCN Operator integrates seamlessly with leading APIs and is accessible to agents with visual impairments. TCN is trusted by Fortune 500 companies and enterprises of all sizes in multiple industries in many countries. For more information, visit https://www.tcn.com/ and follow on Twitter @tcn.

On June 7, 2021, the Consumer Relations Consortium (CRC) submitted a comment to the Notice of Proposed Rule Making issued by the California Department of Financial Protection and Innovation (DFPI) on April 23, 2021, regarding California’s licensing and application requirements. The CRC focused its comment on the definition of “Branch office” and asked the DFPI to clarify that an employee may work from home without the need for a “Branch office” license so long as specific operational and security criteria are met.

In support of its comment, the CRC cited a similar regulation in Maryland and pointed out that allowing employees to work from home is beneficial to both the industry and consumers. Notably, the Maryland regulation is not tied to a public health crisis. Instead, it allows collections employees to work from home so long as specifically laid out data and operational requirements are met. The CRC provided a copy of the Maryland regulation to the DFPI as a potential guide for updating the DFPI’s current definition of “Branch office.”

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The CRC further explained in its comments that allowing employees to work from home benefits consumers by enabling accounts receivable entities to retain quality workers and hire the best people regardless of their geographic proximity to a call center.  Additionally, among other positive impacts, this model benefits the industry by increasing employment opportunities and providing employees greater job satisfaction, which results in a lower turnover rate.

The complete comment submitted by the CRC can be found here.

About the Consumer Relations Consortium

The Consumer Relations Consortium (CRC) is a membership group for forward-thinking organizations that wish to influence the direction of collections compliance, legal strategy, and regulatory policy. The CRC is comprised of more than 60 national companies representing the diverse ecosystem of debt collection including creditors, data/technology providers, and compliance-oriented debt collectors that are larger market participants. Established in 2013, CRC is evolving the debt collection paradigm by engaging stakeholders—including consumer advocates, Federal and State regulators, academic and industry thought leaders, creditors, and debt collectors—and challenging them to move beyond talking points and focus on fashioning real-world solutions that actually improve the consumer experience. CRC is managed by The iA Institute. 

Learn more at www.crconsortium.org.

About the iA institute

The iA Institute is a media company that provides news, education, events and connection for professionals in consumer finance. The iA team believes the value of your time and investment in our content should be undeniable, so we thoughtfully design everything we do with a focus on the details that make a difference. Our initiatives include the flagship website and newsletter insideARM; the Consumer Relations Consortium (CRC) and iA Innovation Council membership groups; the iA Research Assistant and Case Law Tracker premium subscriptions; the iA Strategy & Tech digital conference; and the uniquely engaging annual Women in Consumer Finance event. iA is a certified Woman-Owned business.

Learn more at www.theiainstitute.com.