Most mortgage brokerages do not make cold calls, but they still must comply with the new telecommunications regulations. Those few mortgage brokerages that engage in cold calling to solicit mortgage backed debt consolidation business clearly require access to the National Do Not Call List and must maintain an internal corporate do not call list.
What about the great majority of others that only call past clients or referrals, or call to follow up on new business enquiries initiated by the person they are calling? Many such mortgage brokerages have not yet registered, thinking that there is no need to do so because their activities are exempt. Unfortunately this is not true.
Basically, if you use a telephone for business sales calls then you must register. You do not have to subscribe, but you must register. Registering is your first step in performing due diligence as a defense against mistakes or false accusations. Registration is free.
If you follow up a referral, then you may be relying on the initiative or permission of a third party to make your call. In that case your call would not be exempt, and the number must be checked against the National Do Not Call List (as well as your own internal Do Not Call List). If you don't check, you don't know, and you don't have a defense.
You may not have a company do not call list, but that does not mean you do not need one. Having a company do not call list is the essential second step in performing due diligence. Even if the list is empty now and you never expect it to have even one entry, you must still have that list, have procedures to maintain and distribute it, train your staff in its use and maintenance, and have documentation in place to substantiate your compliance with the regulations. Almost any call you make has some potential, however small, to create a company Do Not Call List (DNCL) entry, especially as public awareness of the regulations increases. That includes calls made in error.
Perhaps you are following up a former client whose five year mortgage will soon be up for renewal. It was more than 18 months ago that you did the business. Their contract is with the mortgagee, and they are making payments to the mortgagee, not to you. Are they safe to call? Is there a business relationship? Will the regulator consider them to be current clients or not? Do you want to be the first to find out?
Because Call Tracker is specifically for the sales professional who rarely cold calls, the pricing structure of Call Tracker allows a brokerage to put all their permission based marketing staff onto the service for free. Call Tracker is an ideal fit for the Mortgage Brokerage business since it
Call Tracker makes it easy to track business relationships and report those that are about to expire. Use Call Tracker to keep on top of these opportunities to expand your permission based marketing activities. If a documented business relationship does not exist, then the National Do Not Call List (National Do Not Call List) should be checked for that number at no less than monthly intervals before calling. Do you have specific permission from everyone on your client list to contact them by telephone?