FTC Workshop: Debt Collection 2.0: Protecting Consumers As Technology Changes, Project No. P114802 #00020 

Submission Number:
00020 
Commenter:
John Tallarico
Organization:
SoundBite Communications
State:
Massachusetts
Initiative Name:
FTC Workshop: Debt Collection 2.0: Protecting Consumers As Technology Changes, Project No. P114802

As the FTC looks to address consumer protection issues resulting from advances in technology, it is imperative to balance the important role that technology serves in the life of a consumer, as well as the efficiency it provides to Businesses, Utilities, Governmental Agencies and Educational Institutions. Since 1977, when the FDCPA was first enacted, there has been a social shift in how people communicate. It is fact that the mobile phone is on its way to becoming the primary contact device and what was once considered the “home phone” is often no longer a wireline device. Regulations need to be adapted to meet the changing consumer communications trends. With more individuals opting for paperless statements and electronic communications regarding their accounts (i.e. credit card, investment, utilities, loyalty, rewards, etc), regular notifications and reminders are essential to keep businesses operating. With an existing business relationship, consumer obligations require a path to readily communicate relevant and time sensitive information. The volume and frequency of consumer desired communications require automated technology in the form of voice, text, multi-media-messaging, email and predictive dialers in order to keep-up with demand and provide timely communications. SoundBite invests significant resources to ensure our technology is compliant with Federal and State regulations while at the same time being sensitive to privacy rights. As a technology innovator, it is our job to educate the market about the purpose and capabilities of our (and similar) technologies. As the FTC adapts new and modified regulations, we urge them to seek out and consult with individuals that understand how the technology is built and managed. Innovation has taken us far in the past 30+ years, and it is a necessity to responsibly regulate this without resorting to manual outreach, which is extremely inefficient. SoundBite Communications fully supports the Commission’s efforts to re-examine how current regulation is written. We are also available as a resource to the Commission to provide education on how newer technology works to make sure capabilities are clearly understood and current. As a society, we must be able to utilize technological advancements and create rules that benefit all constituents – consumers, businesses and the public sector.