FTC Safe Harbor Compliance Checklist:

Every outbound call an employee or contractor dials risks an $11,000 fine unless you meet the requirements outlined in the FTC Telemarketing Sales Rule, these are most of the key steps required to put your business on the path to compliance and well within the Safe Harbor provisions of the new rule. You can't afford to not pay attention to these regulations!

1. Assign the duties of data verification, training, management, and enforcement of the Telephone Solicitation and in-house DNC policies to a member of your staff.

2. Immediately purchase the required licenses for State and Federal DNC lists as needed

3. Determine the local server or web-based solution you will use to manage the Federal, State, and in-house DNC lists. You will need a computerized solution immediately whether it is the permanent solution or a bridge product to get you through research and installation of a different product. Printed solutions are not practical and would mean thousands of pages on every desk. (of course the best choice is OCM & CheckCall http://www.ocmusa.com/ 888-481-3727 we can have you and all your locations online and live in 24hrs or less!)

4. Draft a company Telephone Solicitation Policy & In-house DNC policy & procedures.

5. Draft scripts to address disclosure requirements of outbound calls and those of multiple purpose calls if needed.

6. Train all employees who make outbound sales calls, follow-up calls, or those who may receive a request to add a customer to your in-house DNC list. Training should include FTC & FCC rules along with your Telephone Solicitation Policy & In-house DNC policy & procedures. Document the training to their employee files.

7. Verify any contractors utilize only your companies licensed area codes or states to screen outbound call numbers. Plan and coordinate the constant update & sharing of your in-house DNC list with any contractors. Any contractors must be sure customers are not on your in-house DNC list before calling and be easily able to update it promptly.

8. Review your phone system for needed upgrades if no caller ID is available. It is a violation to fail to transmit the telephone number, and, when available by the telemarketer's telephone company, the name of the telemarketer to any consumer's caller identification service. This provision takes effect January 29, 2004.



Paul DeMoret National Operations Director
1-888-481-3727
info@checkcall.com