Merchant Account Underwriting Tools

ON THE HOOK

For $280 Million! Merchant processors should know what their vendors are doing on their behalf.

“Sellers may be held responsible for illegal calls placed by third-parties that market goods and services on their behalf, especially where the seller has the right to control the third parties and the benefit of the calls flows primarily to the seller.”

“Assuring proper line of sight between vendors placing marketing calls is now essential to assure that internal DNC lists are being shared and scrubbed across vendors,” he said. “(Take) proper note (of) call abandonment and pre-recorded calls (and) double-check scrub processes to assure compliance with TSR’s exemptions before calling numbers on the National DNC. ‘This is how everyone else is doing things’ is no defense. Regulators can still come after you.” Attorney Eric Troutman.

http://cookcountyrecord.com/stories/511129169-dish-network-hit-with-283m-penalty-for-third-party-telemarketing-practices

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