Turning TCPA Lemons into Enterprise Lemonade. Exelon and Neustar Discuss TCPA and Enterprise Phone Management for Utilities

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1 Turning TCPA Lemons into Enterprise Lemonade Exelon and Neustar Discuss TCPA and Enterprise Phone Management for Utilities

2 Presenters Mitchell Young Neustar Exec. Director, Identity Solutions Kindle Cook Exelon Senior Project Manager Neustar Inc. All Rights Reserved 2

3 AGENDA Industry Insights & Neustar Background Customer Phone Numbers & Impact to Utilities TCPA & Outbound Communications Background on TCPA Knowing Your Customer s Identity Exelon TCPA Project 2018 Neustar Inc. All Rights Reserved 3

4 LEGAL DISCLAIMER The information in this presentation was compiled for informational purposes only. No information contained herein is intended to constitute legal advice and accordingly, you should consult with your own attorneys when developing your own programs and policies. We do not guarantee the accuracy of this information or any results. 4

5 Industry Insights & Neustar Background Why Accurate Customer Phone Numbers Are More Important Than Ever 2018 Neustar Inc. All Rights Reserved 5

6 TCPA LAWSUITS Are You Prepared? Largest Lawsuit (by year) 2017: $280M CSP 2016: $76M Travel 2015: $60M Financial Services 2014: $75M Financial Services 2013: $35-$47M Quick Service Restaurant 2.6K K K K Neustar Inc. All Rights Reserved 6

7 CONSUMER DATA IS CONSTANTLY CHANGING Every Year 45M Consumers change their phone numbers 60M People relocate 2018 Neustar Inc. All Rights Reserved 7

8 For over 20 years, a leader in the telecommunications industry: Power 90% of U.S. Caller ID Manage U.S. Directory Assistance N. American Numbering Plan Administrator TCPA Advisor to the FCC 2018 Neustar Inc. All Rights Reserved 8

9 A leader in phone identity management: 10 of Top 10 U.S. Banks Top 3 U.S. Cable TV Providers 8 of Top 10 Insurance Companies 7 of Top 15 Utilities 50% of U.S. Online Retailers Verify Consumer Identity 1.4 Billion Time Each Day 2018 Neustar Inc. All Rights Reserved 9

10 Consumer Phone Numbers & Its Impact on Utilities 2018 Neustar Inc. All Rights Reserved 10

11 PROACTIVELY KEEP CRM DATA ACCURATE & UP-TO-DATE ORIGINAL CRM NEUSTAR CLEANSE/APPEND John Smithe Misspelled Name 19 National Drive McLean, VA Non-Standardized Address Unknown Phone Type Unverified John Smithe Inexact Last Name Match Corrected Name Available 19 National Drive McLean, VA Standardized and Verified: Address belongs to John Smith Type = Wireless Mismatch: Phone does not belong to John Smith Wireless Phone Linked to John Smith. Active Phone. Available. jsmith@gmail.com Verified: Belongs to John Smith john.smith@work.com Additional Available CONTINUOUSLY CORROBORATED 11

12 Neustar Customer Identity Management Account Origination! Emergency Notifications $ Collections Marketing General Notifications Inbound Communications 2017 Neustar Inc. All Rights Reserved

13 Identity Management: Outbound Communications Ensure customers receive messages Improve customer experience Reduce TCPA risk Reduces inbound calls! Emergency Notifications $ Collections General Notifications 2017 Neustar Inc. All Rights Reserved

14 Identity Management: Inbound Communications Increase customer identification Improve customer experience Reduce live agent costs Increase IVR containment rates Inbound Communications 2017 Neustar Inc. All Rights Reserved

15 YOU SPEND BILLIONS TO BE CUSTOMER-CENTRIC $558B Fortune 500 estimated spend on customer experience But who are you really interacting with? Source: Gartner, Fortune 2018 Neustar Inc. All Rights Reserved 15

16 Utilities and The Telephone Consumer Protection Act (TCPA) 2018 Neustar Inc. All Rights Reserved 16

17 FCC 2015 DECLARATORY RULING ON TCPA Two Key Issues for Utilities 1. Definition of Called Party Consent not valid if phone reassigned ( Intended recipient irrelevant) 2. Consent/Revocation of Consent A consumer may revoke consent at any time, through any reasonable means EEI/AGA Petition clarified prior express consent provided at sign-up

18 CONSENT REQUIREMENTS FOR AUTO-DIALING OR TEXT MESSAGING Types of Notifications Examples Consent Required Emergency Notifications Scope is unclear Exempt Informational Notifications Service Outages Meter Work; Field Work Pending Curtailment Subsidized Service Brownouts Prior Express Consent Satisfied if Customer Provides Phone # Telemarketing Messages New Services Scope is unclear Prior Express Written Consent Risk lies in Auto-Dialing a Reassigned Cell Phone 2018 Neustar Inc. All Rights Reserved 18

19 Outbound Customer Communications Knowing Your Customers Identity 2018 Neustar Inc. All Rights Reserved 19

20 PHONE QUALITY: UTILITY INDUSTRY BENCHMARK PHONES 18%-22% Phones Wrong or Disconnected Customers Not Receiving Messages/Alerts Significant TCPA Risk 5% 7% 7% 11% Definition VERIFIED PHONE UNKNOWN 70% BUSINESS PHONE DISCONNECTED WRONG CONSUMER

21 NEUSTAR VERIFICATION FOR TCPA VERIFIED John Smith /1/2015 Name-to-Phone: Verified Phone Type: Mobile Phone In-Service: 12 Months + Disconnected: No 2018 Neustar Inc. All Rights Reserved 21

22 CASE STUDY: RECEIVED COMMUNICATION REDUCES DISCONNECT RATES Challenge: Customers 44% more likely to have service disconnected if they don t receive Disconnect for Non-Payment Call. Solution Neustar Phone Verification and Proactive Change Results $1.6M in wasted truck roll costs identified Improved customer experience Reduced bad debt 2018 Neustar Inc. All Rights Reserved 22

23 CASE STUDY: RECEIVED COMMUNICATION REDUCES INBOUND CALLS Challenge: Customers call-in when they don t receive important outage communications due to wrong numbers. Our Solution Neustar Phone Verification and Proactive Change The Results 5% increase in customer satisfaction scores 7% less inbound calls $1M+ in annual cost savings Less risk to customer health and safety 2018 Neustar Inc. All Rights Reserved 23

24 INBOUND COMMUNICATIONS: AUGMENTING A CRM Utility Customer CRM ANI NOT FOUND Query Neustar 2018 Neustar Inc. All Rights Reserved 24

25 INBOUND COMMUNICATIONS: AUGMENTING A CRM NEUSTAR ACCOUNTLINK NEUSTAR REPOSITORY (Mobile) Utility Customer CRM IMPACT 76% increase in ANI to ANI match 26% increase in IVR containment Reduce live agent costs + improve customer experience Patrick Smith 32 Schindler Place New Brunswick, NJ patrick.smith@verizon.net (Landline) (Mobile) Also in Household: Camille Smith camsmith13@verizon.net Lauren Smith laurensmith@hotmail.com MATCH FOUND: Patrick Smith Camille Smith 32 Schindler Place New Brunswick, NJ Phone: Status: Active Account: Balance: $ Neustar Inc. All Rights Reserved 25

26 The Implementation of a TCPA Solution at Exelon Utilities May 2018 Kindle Cook - Sr. Project Manager

27 Exelon TCPA Project Steps Project goals 2. Developing project team 3. Completing phone scrub of the Customer CRM early 4. Creating inventory of automated calls 5. Determining process for opt-out/wrong number requests

28 1. Project Goals 28 Designed to mitigate risks associated with 7 million customers Over 100 programs that contact customers Millions of customer calls a month Two key issues 1. Wrong/Recycled Phone Numbers Initial and ongoing scrub of phone numbers is important to ensure customer information doesn t contain wrong/recycled phone numbers 2. Consent & Opt-Outs Ensure customer has a reasonable way to revoke consent Technically, be able to track and implement revocations

29 2. Project Team & Legal Sponsorship 29 Exelon Project Team members from each operating company ComEd PECO BGE

30 3. Phone Number Scrub Early & Ongoing 30 Neustar verified if customer still owned phone number Create baseline of consent and phone ownership Wrong/Recycled numbers identified Replace wrong/recycled phone numbers with or blank Impacts of removing wrong numbers Consider regulatory requirements to contact customer not by phone Costs associated with contacting customer to get a new phone number

31 4. Inventory of Customer Calling Programs 31 Outbound calling programs divided into 3 groups: 1. Informational Customer can opt out 2. Marketing Customer can opt out 3. Emergency Customer cannot opt out Note: Regardless of category, all text messages are opt in only Get Legal sign-off on classification

32 4. Inventory of Customer Calling Programs 32 Capture details of Calling Programs Description of activity If made by vendor, vendor s name Call or Text Type of integration Volume estimates for all calling programs Business ownership o Credit and Collections o Marketing o Field o o o Employee Government/External Storm

33 5. Opt-Out & Wrong Number Requests: Landline vs Mobile 33 Landline and mobile phone numbers identified to meet requirements Opt-Out option for following calls: 1. Landline numbers for marketing purposes 2. Mobile numbers for all purposes (except emergency) Wrong Number reporting option offered on all calls -- Emergency, Informational, and Marketing -- for 1. Landline numbers 2. Mobile numbers

34 5. Opt-Out & Wrong Number Request Options & Policies 34 Customer options for updating notification preferences Call the Call Center to inform a live agent Press 9 during an automated call Reply STOP to a TEXT message Press 7 to indicate a wrong number during an automated call Online preference center Live agent must process Opt-Out or Wrong Number, but DOES NOT need to proactively ask Express consent can be collected during customer sign up or during updates to contact information

35 5. Managing an Opt-Out 35 When consent revoked, non-emergency calls/texts stopped Once you opt out of one program, you opt out of all Bill insert used to inform customer of Opt-Out impact Directions on how to opt back in Consent must be re-established before number is used again

36 Final Thoughts & Considerations 36 Maintain within customer system: TCPA opt out list Landline or Mobile Phone indicator If all vendors placing calls/texts don t go live at same time, may want to address risk during the phase-in period Develop a process to add new calling programs or vendors post-project

37 KEYS TO TCPA Capture and maintain proper consent Understand the type of phone you are calling Confirm phone still belongs to intended call or text target 2018 Neustar Inc. All Rights Reserved 37

38 Questions? Mitchell Young Neustar Exec. Director, Identity Solutions Kindle Cook Exelon Senior Project Manager Neustar Inc. All Rights Reserved 38

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