The Compliance department is responsible for reviewing all sales and insuring that they meet the established criteria before any products are shipped, or any billing is initiated. Compliance is also responsible for verifying the accuracy of any banking information collected, and for conducting blind monitoring of agents to help insure that scripts and procedures are followed on all inbound and outbound calls, not just calls ending in sales.

Every sale generated on the sales floor is audited before it is ever processed. Once a customer agrees to review one of our offers, our agent initiates a verification mode and a recording is automatically made of the verification portion of the script. When this verification is complete and the call is finished, a data record is created in the “real time” database, allowing Compliance agents to review the on-line recording within minutes.

A Compliance department agent listens to the verification recording and reviews the data in the real-time record. Each potential sale is coded in one of the following ways: good; write-up (a minor infraction occurred, but the sale is able to be processed and the sales agent is provided with a write-up on the incident); or kick-out (the sale should not be allowed to be processed and the sales agent is provided with a write up on the infraction). While a sale is being reviewed, the Compliance agent is charged with making sure that:

• Permission to record was stated and received
  
  
• Customers name, address, and phone number are verified
  
  
• Customers billing info is received and verified
   
• We have permission to bill the customer’s account.
  
  
• All terms and conditions clearly verified with customer
  
  
• Customer fully understands all trial and billing cycles

The Sales floor receives several reports on the status of their past and current production.  For instance, all Sales floors regularly monitor the “RTSD” (Real Time Status Display). This provides the Sales managers with many tools, including how many sales have been coded for a particular Sales agent, what the status is of the sale (good, write-up, kick out, or pending), and room-to-room comparisons. With this report a Sales manager can also go back and see the production and status of the previous day's work.

If a sale is deemed to be a kick out and is not able to be processed, then instantly a “kick out sheet” will print out on a printer in the appropriate Sales room, explaining the infraction, so the deficiency can be addressed with the Sales agent almost immediately,  and the problem be rectified.  If appropriate, the prospect is called back and a clean verification is recorded. At the end of each day a “problem report” is generated for each room which contains detailed descriptions of all kick outs and write ups for all agents.

If no recording is available for review, Compliance attempts to locate the recording file (in case it was miscoded by the recorder).  If they cannot locate a recording, the sale is kicked out until the prospect can be called back and a valid verification recording made.

Internal Compliance Procedures

Live-monitoring is another tool used by the Compliance department, in which agents are monitored before they go into the recorded verification with the customer to monitor script compliance and general demeanor.  We randomly live-monitor Sales agents in all rooms, including Customer Service and the inbound CallerID room, and also perform directed monitoring when we receive a customer complaint in regard to a specific agent.

Directed monitoring can be initiated by calls to Customer Service or our CallerID room, or when an agent accumulates a series of infractions or kick outs that are beyond norms.

In addition to review of all sales recordings and blind monitoring of sales agents, the Compliance Department staff one Merchant Processing Representative (MPR) on each sales floor.  The MPR’s duties are to verify the ABA routing numbers for prospective customer bank accounts using the Thompson Global Banking Resource, and the individual account numbers using Veri-Check, when possible, in order to make sure that the information is valid.  If the information cannot be verified at the time of sales, MPR’s will call the bank to verify the account information. If the account is invalid the customer must be re-called, and new account information pulled and re-verified before any deal is considered valid. 

All valid deals are entered into a “bank call-in” system.  All deals must have a print out from Veri-check system showing status of the account stapled to the printed sales record.

In addition to Compliance department procedures, some technical means are used where possible to guard against agent fraud.  Sales agents cannot manually dial any outbound phone calls, or control the naming of recording files, and the act of initiating a recording is marked in the system database.  Out-pulsed ` digits are tied to particular rooms to facilitate tracking agents quickly in case of any complaint where the agent name is not immediately known.  Any manual callbacks to customers required to re-verify invalid deals are restricted to dedicated agents who are approved by the Compliance department.