By Jenniffer Cabrera
R . E . A . C . H INSIGHTS
INDUSTRY RESPONDS
R . E . A . C . H . SET TO EVALUATE NEW STANDARDS IN LIGHT OF FTC TSR CHANGES AND REASSIGNED
NUMBERS DATABASE
By Jenniffer Cabrera
SO we have been covering quite a few moving pieces in the lead generation world recently .
Today Responsible Enterprises Against Consumer Harassment ( R . E . A . C . H .) announced it would be exploring modified standards that would prevent the use of prerecorded calls to contact purchased leads — consistent with the FTC ’ s new guidance .
R . E . A . C . H . is also exploring requiring all lead purchasers to use the reassigned numbers database to place calls if a lead is more than 60 days old .
Finally , R . E . A . C . H . may mandate that all member callers have an assigned SAN in order to scrub the national DNCR .
Proposed language implementing the changes is below .
You can read the full current standards by visiting this link : tcpaworld . com / wp-content / uploads / 2023 / 09 / REACH- Standards-Formatted . -Feb-2023 . pdf .
R . E . A . C . H . will be bringing these new modifications — if adopted — to the
FCC for consideration this month in connection with the pending NPRM .
For more information on joining R . E . A . C . H ., visit reachmbc . com .
Proposed changes :
9 . REQUIRED USE OF REASSIGNED NUMBERS DATABASE BY GSP AND MLP
Any GSP and MLP shall subscribe to and use the Reassigned Numbers Database offered by the Federal Communications Commission for any campaign including calls to numbers obtained 60 days or more prior to the consent event date or last “ good date .” For purposes of this paragraph “ good date ” shall mean the last date the GSP or MLP or any MLS from which a number was obtained reached the intended consumer on the number dialed .
The GSP or MLP need only scrub the numbers within any given campaign that exceed the 60 day threshold provided above . The GSP or MLP shall assure that such numbers are re-scrubbed not later than every 30 days thereafter .
The GSP or MLP can create reasonable procedures to perform scrubs via a monthly batch process or other means that assure substantial compliance with this provision .
The GSP or MLP shall use reasonable means to assure that all numbers noted as a “ Y ” by the database administrator are removed from the campaign and no longer called .
10 . REQUIREMENT TO USE INDIVIDUAL SUBSCRIBER ACCOUNT NUMBER FOR NATIONAL DNC REGISTRY ACCESS
Any MLS , MLP or member GSP shall obtain a separate and unique Subscriber Account Number ( SAN ) as required by federal law and regulations to gain access to the National DNC Registry .
17 . PROHIBITION ON USE OF PRERECORDED CALLS AS INITIAL CONTACT OR TO CONTACT ANY PURCHASED LEAD FOR MARKETING PURPOSES
12 • TROUTMANAMIN . COM