Texting loan customers billing and past due notice

Posted By: CM-Compliance

Texting loan customers billing and past due notice - 11/12/14 03:03 PM

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
Posted By: AudOne

Re: Texting loan customers billing and past due notice - 11/12/14 03:28 PM

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.
Posted By: John Burnett

Re: Texting loan customers billing and past due notice - 11/12/14 04:12 PM

I think that it's important to consider that customers may not be all that careful about who can see those texts.
Posted By: CM-Compliance

Re: Texting loan customers billing and past due notice - 11/12/14 05:28 PM

Thanks for the information!
Posted By: ahou

Re: Texting loan customers billing and past due notice - 11/14/14 12:24 AM

Better check state law.
Posted By: Andy_Z

Re: Texting loan customers billing and past due notice - 11/14/14 11:56 PM

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.
Posted By: T42

Re: Texting loan customers billing and past due notice - 10/16/19 09:32 PM

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?
Posted By: Andy_Z

Re: Texting loan customers billing and past due notice - 10/24/19 02:30 PM

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.