Do you think calling back Members to help them complete an Abandoned Application should comply with Tele-Marketing rules?

My Take:

1. Calling back customers to help open the account is a Service Call and not a Sales or Marketing Call. So it is not required to comply with Tele-Marketing rules.

2. You can display a Disclosure for customers mentioning that they are Opting-in to receive a Call or Get an Email to help with the Application when they click "Next" on the application.

What are your thoughts?



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  • CU Employee

    General: (i) Telemarketer shall register itself with TRAI and obtain a registration number.

    (ii)Every Telemarketer would have only single registration for all his telemarketing centres throughout India. 


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  • CU Employee Community Chair

    Is your assumption, Rajesh, that a telephone call is a superior form of service extension than an e-mail (not constrained by the TCPA) that calls attention to the incomplete application and invites the applicant to call a direct dial number for assistance? That's the more interesting question to me. Presumably an application that collects phone number can just as quickly collect e-mail address. Using the latter leaves the member with greater latitude to engage the CU at whatever time is most convenient to them, and would therein seem to show greater respect.

    But if it's demonstrably less successful, then, sure -- the decision to make the outreach phone call comes down to your CU's appetite for risk.

    The concern you may hear about the opt-in disclosure button is that it's not expressly WRITTEN consent to receive the phone call, which is the standard that I think applies in many cases like this (a truly cruel, antiquated burden). But, in fairness, the button does demonstrate some good faith effort to set the user's expectations and that may count for something. 

    In my mind, compliance gray areas like this one always comes down to risk appetite — it's never so much what we think is or isn't compliant... it's whether we expect the applicant (and his/her lawyer, and whatever judge/regulator) considers the action compliant. I've not heard of judgments brought against these particular types of telephone outreach, so maybe this case is lower risk than many. But different CUs will see the risk differently, I expect, so conservative as many tend to be.

    Dale Davaz
    STCU R&D Strategist
    CULytics Community Chair

    • Vendor

      Thank you Dale Davaz, 

      Phone Call or Email decision is made on the basis of Lead Scoring and the scoring can be based on what product they selected and where they abandoned. A phone call for high-value applications makes sense, while an automated email for low-value leads will work. 

      I agree that email might be more convenient for members who are not in a rush but, some members would want the Credit Union to call and it might be in the interest on the Credit Union to make a phone call since the conversion rate will be high.

      If we are able to prove that the call was made to help the customer complete their application and also have the ability to show that the member consensus was captured explicitly, we might be ok to call.  The worry is it we categorize as Tele-Marketing call, the can of worms is already opened. and we have to do the right thing.




  • CU Employee CULytics Founder

    Hi Rajesh,

    This is a very good question. I typically see that if someone abandoned their application after initiating it and providing their phone number, then it should be considered a service call. Few years back, I was trying to open an account with one of the leading brokerage firms and for some reason did not complete the application. I got a call within 2 min from them and the rep helped me complete my application. I am still with them and they have been excellent with their service.

    However, if someone abandoned their application without providing their phone number then I would consider it improper if the organizations get my phone number from some 3rd party (they do exist) and then call me. In that case I would find it offensive.

    I am open to hear what others think.


    • Vendor

      I agree, no hunting for contact information. 

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