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Internal Customers-Run FTC Do-Not-Call List?

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Question: 
If we are calling a current mortgage customer to let them know they may qualify for a lower rate with a refinance, are these internal customers required to be ran through the FTC Do-Not-Call list?
Answer: 

If the primary purpose of your outbound call is a solicitation, then yes, you should verify the customer is not on the FTC Do Not Call list. If the primary purpose of your call is services of existing account relationship, but has an added component of solicitation, you would not be subject to the customer's presence on the Do Not Call list, but still a best practice to ask customer's permission to share the solicitation information. For example, "While I have you on the phone, I see that you may qualify for a lower rate with a refinance. May I share with you more information on how you can take advantage of this?"

First published on 11/05/2017

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