Please forgive the double post, but maybe I will get some responses here.

We are planning to have a vendor call our customers, survey them to see if there are any additional bank products that they might be interested in obtaining. Our employees will then call the customer.

I think I am ok on Do Not Call because they are already our customers. I think I am ok on Privacy because it is our bank products that we are offering, not a third party or affiliate. This is not an opt out issue, right?

Since this is the first time that we have done something like this, I wanted to make sure that I am not missing anything. Can we proceed or is there another reg to consider?

Thanks in advance for any guidance - suggestions

Help, please. Or point me in the right direction. Thanks.

I read an article this year on a company getting hit with big fines for soliciting people on the national do not call list. I believe they purchased leads from the CR and thought they were safe. Maybe call your regulator for clarification.
--snip
In a March 1, 2005 news release the FCC has proposed a $770,000 fine against a mortgage company as they made calls to numbers listed on the National Do Not Call list.
The FCC wants the maximum fine for each of the 70 violations, $11,000 each
--
Ive never been 100% clear on the exception for current customers.

the opt out rules, from what I remember, only apply to firm offers of credit or insurance, think only by mail too.

Thanks for responding.

As I recall, if they are your current customers, you can call them regardless of whether or not they are on the Do Not Call list. It's prospective customers that you have to check the list for. Anyone aware of anything different?

Keep the posts coming, bank is signing agreement.

If your existing customers ask you to cease calling them, then you must remove their names from the call lists. You would need an internal do not call list.

why would you sign with an outside vender for someting like this. Depending on your bank size and appearance you want to present to your customers....
leads like this can be disbursed to branchs and done internally, 1 call a day, and now the customer is prob talking to some one they know vs getting called by an external group. How many of your customers will hang up or think they are getting scammed.....

how much is this outside group charging you vs the bank rewarding its employees, say $1 for each success (defined) cross-sell for your existing customers.
Now since this is a new contract, you do have to worry about the FACT ACT disposal of consumer information in your contract.

Good questions, however Marketing and Sr mgmt made the decision. The vendor surveys the customers to determine satisfaction with the bank, bank products, and get suggestions, etc. If the customer indicates that there is a product that they might be interested in, we are notified and we will call them. As I understand it, the primary focus is survey regarding satisfaction.