TCPA
UDAAP stands for ______
What is Unfair, Deceptive, or Abusive Acts and Practices?
LOA stands for _____
What is Letter of Authorization?
TPPA stands for _____
What is Third Party Payment Authorization?
Compliance training is done on a _____ basis
What is quarterly?
TCPA was created to stop calls from this group, which Lift Credit does not fall under
What is telemarketers?
UDAPP is created to establish protection for this group of people
Who are consumers?
LOA alone does not allow to save this to the account
What is a 3rd Party payment method (DC/ACH)? Need LOA & TPPA.
These parties need to physically sign the TPPA document
What is the customer and 3rd party payment account holder?
Score that you must get on the Comprehensive Compliance Training to pass
What is 70%+?
TCPA was designed to do this
UDAAP is closely linked to these 2 other regulations, related to when a customer obtains a loan
What is ECOA and TILA?
TILA requires creditors to “clearly and conspicuously” disclose the costs and terms of credit.
A discriminatory act that is unfair, deceptive, or abusive may also violate ECOA.
We add LOA information to a customers account by saving name, phone, and email in this section in PLM
What is Spouse Information section?
TPPA allows these 2 actions on an account
What are
The 3rd Party can add and save their own specific payment method to the account for future use.
The 3rd Party can turn their own specific payment method on auto-pay.
Name 2 regulations we train on that are not mentioned today
What are:
SCRA, MLA, FCRA, FDCPA, GLBA, EFTA, NACHA (TILA/ECOA)
Lift Credit stays in compliance for TCPA with these 6 rules
What is
Calling at correct times. We still follow the 8a-9pm in their timezone.
Honoring cease and desist requests
Identifying ourselves: company name and phone number.
Providing options to opt out of texts and emails.
Receiving prior express consent in our loan agreements to call and text.
We don’t use robo-calls or auto dialers for soliciting.
4 examples of UDAAP that apply to Lift Credit
What are
1. Revealing the consumers debt to employer without the consent of consumer.
2. Misrepresenting that a debt collection communication is from an attorney.
3. Misrepresenting that a debt will be waived if they accept a settlement offer which the company does not in fact, waive the debt.
4. False threats of lawsuits, arrest for non-payment of a debt.
Check this dropdown in PLM to see if we have LOA on an account
What is Additional Agreements?
These are 3 general rules for accepting TPPA
What are
The LOA process has to be completed prior to starting TPPA steps.
The TPPA document will not be accepted unless it’s handwritten.
If you see a 3rd party card on file, with no TPPA, delete the card until we get a signed TPPA.
Lift Credit does regular compliance/security training and audits for these 4 reasons
What are
Could lead to identity theft for our customers
Could cost the company millions of dollars
Could cost you your job
To ensure we build trust with our customers! They are trusting us with their personal information.
Lift Credit does not have to honor the National Registry due to this
What is an Established Business Relationship?
Because we have a relationship with the customer we can keep our own DNC list and put the customer on it if requested.
What is anything that
Is likely to cause substantially injury to consumers
Is not reasonably avoidable by consumers
Entices the consumer to choose something harmful because of a different benefit they might gain.
Likely to mislead consumers
Is too confusing and makes the consumer's decision making process difficult.
Is missing important information that is considered material to making a decision.
LOA allows Lift Credit to do these 5 actions
What are
Lift Credit can speak to the 3rd party about ALL loan details including past history/loans.
We can discuss future qualified amounts if they qualify/we know this information.
3rd Party can make payments on Customer’s account using either their ACH/DC payment method as a one time use or the current saved payment methods on the Customer’s account under the Customer’s name.
3rd Party can add/delete payment methods in the Customer’s name
3rd Party can ask us to turn Customers’ auto payments on or off.
This location houses the TPPA document that must be sent to the customer via ____ email in a ___ format
What is Google Drive? What is PLM template? What is PDF?
Name 2 things that Lift Credit includes in the Compliance Program
Written standards, policies, procedures in internal manuals
Monitoring and scoring QA system
Regular, effective training and education for employees
Periodic audits or other methods to monitor compliance
A process to receive complaints concerning possible violations
A process to respond to allegations and enforcement of disciplinary action