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#1975686 - 11/12/14 03:03 PM Texting loan customers billing and past due notice
CM-Compliance Offline
Member
Joined: Oct 2011
Posts: 54
Missouri
Our bank is interested in reaching out to loan customers by text message about upcoming payment due dates and past due messages. Any issues that I need to worry about before this gets started?

Thanks

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eBanking / Technology
#1975701 - 11/12/14 03:28 PM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
AudOne Offline
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AudOne
Joined: Nov 2014
Posts: 9
Texas
The last bank I was at wanted to do this, but they hadn't gotten consent from the customer. They were in the process of adding consent language to their loan application templates when I left. TCPA is the guiding regulation for this.

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#1975716 - 11/12/14 04:12 PM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
John Burnett Offline
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John Burnett
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Posts: 38,481
Cape Cod
I think that it's important to consider that customers may not be all that careful about who can see those texts.
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#1975751 - 11/12/14 05:28 PM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
CM-Compliance Offline
Member
Joined: Oct 2011
Posts: 54
Missouri
Thanks for the information!

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#1976322 - 11/14/14 12:24 AM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,090
Better check state law.
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#1976661 - 11/14/14 11:56 PM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
Andy_Z Offline
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Posts: 27,016
On the Net
TCPA as AudOne pointed out is my first issue. If you're not sending out notices required to be in writing by federal law/reg E-SIGN isn't an issue but you could look at your states UETA just in case.

I will say that somewhere along the line I signed up with a credit card I have and I get a notice that payment is due in 10 days, followed by an email that it's due in 10 days and I worry what would happen if I was actually past due. So please ensure the customers know what will come and when.
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#2223855 - 10/16/19 09:32 PM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
T42 Offline
Junior Member
Joined: Feb 2014
Posts: 49
Illinois
Any updates in this area? Slow to the idea, but considering what hoops we would have to jump through. Also - is there software that runs this process?
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#2224316 - 10/24/19 02:30 PM Re: Texting loan customers billing and past due notice [Re: CM-Compliance]
Andy_Z Offline
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No idea on the software but in 5 years I believe it is more and more common to allow a customer to opt into some notices and increasingly get this info from an app on a handheld device from the FI. Certainly there is more integration there, but an email or text that says "you have a new message on your XYZ app" adds security and privacy.
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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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