TCPA Consent Status

The Telephone Consumer Protection Act (TCPA) prohibits an auto-dialer from calling or sending SMS messages to cellular phones without consent. To be in compliance with the standards set forth by TCPA, Temenos Infinity supports the ability to set the TCPA Consent status of a person's phone number.

In some instances, a person may provide a cellular phone number as a home phone number. In these instances, TCPA consent must still be attained.

A process exists that allows institutions to easily identify cellular phone numbers that were misclassified as home phone numbers. For more information, please see the Phone Number Classification topic in the Administrator Guide.

TCPA Consent Field

The TCPA Consent field is available within the Person Phone panel, and allows users to view and maintain the TCPA Consent status of person's phone number. This field may be set manually by a Temenos user, or automatically through a dialer script or Standard TCPA Import. The TCPA Consent field may have the following values:

Value

Description

<blank>

An attempt to attain TCPA consent has not been made.

By default, the TCPA Consent field is blank.

Yes

Account holder has given consent to contact the phone number.

Account holder has denied consent to contact the phone number.

Unknown

An attempt to attain consent was made, but an affirmative response or denial was not received.

To modify this field, navigate to the Person Phone panel. Open the edit screen associated with the Person Phone panel, click within the TCPA Consent field, and select the appropriate consent status. Once a status has been selected, save the edit screen.

Dialers

Phone numbers with a TCPA Consent of No are not included in dialer campaigns. Phone numbers with a TCPA Consent of <blank>, Yes, and Unknown may be included in dialer campaigns. It is up to an institution to configure whether accounts with these responses are included in a dialer campaign.

Financial institutions have the ability to create an OPTOUT dialer return code. The code can initiate a workflow to change a custom field used in queuing logic to restrict accounts from being sent to the dialer.

If an account holder Opts out of future contacts during a dialer campaign, the applicable phone number's TCPA Consent status is set to No and the number is not included in future dialer campaigns.

The handling of TCPA Consent varies by the dialer used by an institution.

Standard Dialer

The Standard Dialer uses three fields to capture a debtor's TCPA consent: HomeTCPAConsent, WorkTCPAConsent, and MobileTCPAConsent. These fields are included in the Standard Dialer Export Process, if the Include TCPA Consent Indicator parameter is set to True within Temenos Infinity's database.

Custom Dialer

Institutions are able to include the HomeTCPAConsent, WorkTCPAConsent, and MobileTCPAConsent fields in the dialer output file. Institutions are able to modify their dialers to use these fields to prevent calling these numbers going forward.

Genesys

When Genesys calls a debtor, the script executes as outlined in the Script document. Once the script completes, the debtor is prompted to indicate if he or she would like to opt out of future automated calls. If the debtor chooses to opt out, the Genesys workflow has two potential outcomes that depends on whether the script has direct connect enabled on it.

For more information on how Genesys handles TCPA Consent and customer Opt Outs, please refer to the Genesys connector guide.

TCPA Import

The TCPA Import updates the TCPA Consent status of existing phone numbers within Temenos Infinity based on data provided in an input file. This import is controlled the IMPORT_TCPA_CONSENT process, which is activated and maintained in Temenos Infinity's database.

By default, the IMPORT_TCPA_CONSENT process initiates daily at 6:45 AM; however, the start time and frequency may be updated by a Temenos Customer Care Representative within the database. Additionally, the IMPORT_TCPA_CONSENT process is dependent on the completion of the core payment import processes as well as Profile Import.

If a dependent process fails or exceeds beyond scheduled runtime, the TCPA Import will not initiate and will wait for the completion of the dependent process.

The IMPORT_TCPA_CONSENT process also has two associated process parameters that control specific behavior within the process. These parameters are also maintained in Temenos Infinity's database.

Process Parameter

Description

TCPA_IMPORT_SHARE

The TCPA_IMPORT_SHARE parameter provides the network location where documents will be available for import process.

TCPA_Account_Restrict

The TCPA_Account_Restrict parameter controls the restriction level of the phone number comparisons. This parameter includes the following options:

ACCOUNT - Compares the import file phone numbers to phone numbers that are assigned to an account number.

For more information on the direct phone number comparisons, please refer to the Input File Layout and Mapping section below.

PHONE - Compares each phone number in the import file against every phone number within Temenos Infinity.

ACCOUNTLOAN - Compares each phone number in the import file against phone numbers associated with the loans on an account, not just the account itself.

The ACCOUNTLOAN option is currently not supported.

Once the import runs successfully, the pipe-delimited file named TCPA_Account_Update_<YYYYMMDD>.txt is archived in the location identified in the TCPA_IMPORT_SHARE process parameter.

Process Exceptions

During this process, the system uses the following logic to evaluate whether or not an exception exists:

If

TCPA consent status fails to update the database
OR

All phone numbers on file record do not exist

Then

Add record to the exception file.

If the process successfully runs but exceptions exist, all exceptions are written to the TCPAImportExceptions.csv. This file is written in the same format as the original TCPA input file and is saved in the location identified in the TCPA_IMPORT_SHARE process parameter.

For more information on the input file format, please refer to the Input File Layout and Mapping section below.

Within the database, institutions have the ability to configure emails to be sent if an exception has occurred.

Process Failure

The TCPA import will fail if the initial or daily file process fails, or no file is present.

Within the database, institutions have the ability to configure emails to be sent if the TCPA import process fails.

Input File Layout and Mapping

Position	Field Format	Field Description	Field Path	Notes
1	Numeric	Account Number	Account > Account Number
2	Numeric	Loan Number	Account > Loan Number
3	Alphanumeric	Variable Field 1
4	Alphanumeric	Variable Field 2
5	Numeric	Phone Number 1	Account > Persons > Phones > Home Phone > Phone Account > Persons > Phones > Work Phone > Phone Account > Persons > Phones > Mobile Phone > Phone Account > Persons > Phones > Other Phone > Phone	Match Phone number against all existing phone numbers within Temenos Infinity.
6	Numeric	Phone Number 2	Account > Persons > Phones > Home Phone > Phone Account > Persons > Phones > Work Phone > Phone Account > Persons > Phones > Mobile Phone > Phone Account > Persons > Phones > Other Phone > Phone	Match Phone number against all existing phone numbers within Temenos Infinity.
7	Numeric	Phone Number 3	Account > Persons > Phones > Home Phone > Phone Account > Persons > Phones > Work Phone > Phone Account > Persons > Phones > Mobile Phone > Phone Account > Persons > Phones > Other Phone > Phone	Match Phone number against all existing phone numbers within Temenos Infinity.
8	Alphanumeric	Phone TCPA Consent 1	Account > Persons > Phones > Home Phone > TCPAConsent Account > Persons > Phones > Work Phone > TCPAConsent Account > Persons > Phones > Mobile Phone > TCPAConsent Account > Persons > Phones > Other Phone > TCPAConsent	Yes/No/Unknown/<Blank> Apply TCPA Consent update against corresponding TCPA Consent status for any phone number match within the system.
9	Alphanumeric	Phone TCPA Consent 2	Account > Persons > Phones > Home Phone > TCPAConsent Account > Persons > Phones > Work Phone > TCPAConsent Account > Persons > Phones > Mobile Phone > TCPAConsent Account > Persons > Phones > Other Phone > TCPAConsent	Yes/No/Unknown/<Blank> Apply TCPA Consent update against corresponding TCPA Consent status for any phone number match within the system.
10	Alphanumeric	Phone TCPA Consent 3	Account > Persons > Phones > Home Phone > TCPAConsent Account > Persons > Phones > Work Phone > TCPAConsent Account > Persons > Phones > Mobile Phone > TCPAConsent Account > Persons > Phones > Other Phone > TCPAConsent	Yes/No/Unknown/<Blank> Apply TCPA Consent update against corresponding TCPA Consent status for any phone number match within the system.