Are You Addressing Critical Compliance Procedures?

Wow, the last three years of TCPA news seems like a blur. Everywhere I turn clients are asking about the TCPA and telling me about the impact it is having on their organization.

The TCPA and class action lawsuits certainly deserve your attention; but, don’t let it distract you from other important components your organization must have in place to remain in compliance with the TSR, TCPA and state telemarketing rules.

In the previous post, Mackenzie shared some great insight on what organizations must do to meet the FTC’s DNC Safe Harbor requirements. If you haven’t checked it out yet, I highly recommend doing so by clicking here. In this week’s post, I’ll dive a little deeper into the training requirement and how vital it is to your organization’s compliance posture and public image.

Prior to beginning their regular duties, DNC training should be provided to agents and anyone else likely to interact with customers and prospects on the phone. Thereafter, we recommend at least annual refresher training. DNC training should at minimally cover the following topics:

  • The corporate DNC policy,
  • how to honor a consumer’s request for the DNC policy,
  • how to honor a DNC request,
  • the process for escalating irate consumers; and
  • disclosure requirements.

Training should be documented with a formal schedule, topics discussed as well as records of attendance. Records can be in any format that is reasonable for your business practices; however, we do recommend maintaining records in a format that is readily available. We recommend ensuring your organization can demonstrate who lead the training, who attended the training, what the training covered, the physical training documents associated with the training and the date/time of the training.

Training should also include how to disposition calls appropriately including how to handle wrong party contacts. This will allow your organization to maintain an accurate consumer database and to take advantage of the FCC’s one call exemption if your organization contacts the wrong party when calling wireless numbers with an ATDS. Obviously, this training can expand to calling times, a cell phone policy, call attempt policies, sales skills, the CRM, HR policies, etc.

We help our clients build robust training presentations and record keeping practices to ensure that compliance is at the forefront of their organization. By building a solid training program, your organization can ensure it is meeting a key component of DNC Safe Harbor, strengthen your organization’s compliance with the TSR, TCPA, state telemarketing rules. Furthermore, agents on the front line will be better prepared to professionally represent your organization and the brand that has taken so much hard work to build.

For more information on how to ensure your employees and vendors are trained on critical compliance procedures, please contact us at

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