PFP/SCHMITT SUSSMAN ENTERPRISES, INC.
DO NOT CALL POLICY- 2006
PFP will adhere to all applicable and enforceable federal and state laws and regulations governing outbound telephone calls for the protection of the privacy of telephone consumers. PFP has implemented this Do-Not-Call Policy to provide the guidelines necessary to follow all applicable and enforceable federal and state Do-Not-Call laws. If you have any questions about the applicability of this Do-Not-Call Policy to any operations at PFP, please call the Member Benefit Communications Department at 1-800-990-7890 ext 1165.
The federal government, through the Federal Communications Commission ("FCC") and the Federal Trade Commission ("FTC"), and several states have enacted laws governing how companies contact consumers through use of the telephone. These laws generally cover the following areas: (a) Do-Not-Call Lists; (b) Do-Not-Call List Exceptions; (c) Company-Specific Do-Not-Call Lists; (d) Use of Automated or Predictive Dialers; (e) Use of Artificial or Prerecorded Voices; (f) Abandoned Calls; (g) Wireless Telephone Numbers; (h) Caller ID Requirements; (i) Time-of-Day Restrictions; (j) Sales and Upsell Disclosures; and (k) Facsimile Restrictions.
The following guidelines prepare PFP employees to follow applicable and enforceable federal and state Do-Not-Call laws. Each jurisdiction, however, may have certain laws that differ from these general policies. To the extent that federal and state laws may change, PFP may change, revise or alter these guidelines. Employees involved with activities affected by these guidelines will receive training to enable them to take actions consistent with these guidelines.
Do-Not-Call Lists. The federal government and several states have adopted "Do-Not-Call" lists that allow consumers to place their numbers on a list that prevents telephone solicitations, except in certain limited circumstances. When necessary, PFP will subscribe to applicable federal and state Do-Not-Call lists and will scrub the numbers against those applicable lists, subject to applicable exceptions.
Do-Not-Call List Exceptions. Most Do-Not-Call laws allow businesses and other entities to make telephone solicitations to certain consumers even though their number may
appear on a Do-Not-Call list. Generally, these exceptions apply to (1) businesses with an "Established Business Relationship" with the consumer; (2) a consumer who has specifically consented to allow the business to call him or her; (3) charitable organizations; and (4) political entities. Given our business, the Established Business Relationship exception will apply most frequently to the activities we undertake for our clients. PFP may contact consumers that fall within these exceptions, based on information received from each client.
Company-Specific Do-Not-Call Lists. Do-Not-Call regulations allow a consumer to place his or her telephone number on a Company-Specific Do-Not-Call List that prohibits a business from contacting that consumer even if the consumer and the business have an Established Business Relationship. Typically, a consumer’s Company Specific Do-Not-Call Request will become effective 30 days after the consumer makes the request. PFP will honor Company-Specific Do-Not-Call Lists based on information provided by the consumer.
Use of Automated or Predictive Dialers. These laws dictate when and how PFP can use automated or predictive dialers to call consumers. PFP will not use automated or predictive dialers to place telephone solicitations. Should this situation change, PFP will comply with FCC rules
Use of Artificial or Prerecorded Voices. These laws dictate how and when PFP can use artificial or prerecorded voice services to call consumers. PFP will not use automated or prerecorded voices to place telephone solicitations. Should this situation change, PFP will comply with FCC rules
Abandoned Calls. Under the FCC’s rules, when using an automated or predictive dialer PFP cannot disconnect an unanswered telephone solicitation call, when using an automated or predictive dialer until either 15 seconds have elapsed after the first ring, or after four (4) rings. The FCC classifies a telephone solicitation that does not meet these requirements as an "abandoned call". PFP will not use automated or predictive dialers to place telephone solicitations. Should this situation change, PFP will comply with FCC rules regarding abandoned calls.
Wireless Telephone Numbers. PFP will apply all FCC Do-Not-Call rules (for example, National Do-Not-Call Registry, Company Specific Do-Not-Call Lists) to wireless telephone numbers.
Caller ID Requirements. PFP will not block Caller ID information. In accordance with the FCC rules, PFP will transmit Caller ID information .
Time of Day Restrictions. Representatives of PFP will not place telephone solicitation calls to a residential telephone number before 8:00 a.m. or after 9:00 p.m. Monday thru Saturday (local time at the residential telephone number location) Sunday 9:00am –9:00pm . In making telephone solicitation calls to those states that have enacted applicable and enforceable time of day restrictions that are stricter than the FCC rules, PFP will follow the stricter guidelines.
Identification of Telephone Solicitation
Persons representing PFP for purposes of telephone solicitations must clearly state the name of the organization, their name, the purpose of their call and provide to the caller a telephone number through which PFP may be contacted.
Sales and Upsell Disclosures. For all outbound calls that include a sales or an upsell component, PFP must provide required telemarketing disclosures prior to the sales communication. These required disclosures include truthfully disclosing material information in a clear and conspicuous manner before a consumer pays for a good or service and obtaining the consumer’s express, verifiable authorization for payment.
Facsimile Restrictions. PFP will not dial any telephone number for the purpose of determining whether the line is a facsimile or voice line. PFP will not use facsimile machines, computers or any other device to send "unsolicited advertisements" to any telephone facsimile machine.
Do-Not-Call Training. PFP requires employees directly involved in the placement of outbound telephone solicitations to undergo training on this Do-Not-Call Policy. All inside sales and service personnel will be instructed in training sessions or by a supervisor to respond to client who wishes to be placed on the Do Not Call list. All inside sales and service personnel will be required, after being trained in the procedures and the content of the guidelines, to sign an acknowledgement that they understand the guidelines and their importance.
Handling Do-Not-Call Questions. During a telephone call with a customer, employees may encounter requests: (a) for information about Do-Not-Call legislation; (b) to be placed on the National Do-Not-Call Registry; (c) to be placed on a state Do-Not-Call list; (d) to be placed on a Company-Specific Do-Not-Call List; or (e) for a copy of PFP Do-Not-Call Policy. Please handle each of these requests in accordance with the procedures set out below. If you receive a request from a consumer that does not fall within any of these categories, please contact your supervisor immediately.
Requests for Information about Do-Not-Call Legislation. Unless instructed otherwise by PFP, please direct the customer to the FCC’s telephone number at 1-888-225-5322 or the FCC’s website located at http://www.fcc.gov/cgb/donotcall/
Requests to be placed on the National Do-Not-Call List. Unless instructed otherwise by PFP, please direct the customer to the FCC’s Do-Not-Call telephone number at 1-888-382-1222 or the FCC’s website located at http://www.donotcall.gov.
Requests to be placed on a State Do-Not-Call List. Unless instructed otherwise by PFP, please direct the customer to the state government website for the state referenced by the customer. Generally, state websites are located at www.nameofstate.gov .
Requests to be placed on a Company-Specific Do-Not-Call List. Please ask for the consumer’s name, telephone number, social security number and the name of their credit union. You will be instructed in your training session how to input this information into the company do not call database.
Requests for a Copy of This Do-Not-Call-Policy. Please ask for the consumer’s name and address and forward that information to the PFP Member Benefit Communications Department . PFP will then send a copy of the Do-Not-Call Policy to the consumer.
These guidelines serve as PFP’s written Do Not Call Policy as required by the FCC Rules.
Document dated January 2006