CONSENT IS NOT ENOUGH: What Every Contact Center Must Know About Recent TCPA Rulings Tom Nowaczyk Director, Product Management Neustar, Inc PACE CONVENTION & EXPO | APRIL 3-6 | ORLANDO, FL #16PACE

#16PACE Topics we’ll cover TCPA – Why You Should Care Review of TCPA & Recent FCC Declaratory Ruling Applying TCPA Guidelines Managing Your TCPA Risk Q & A Copyright © 2016 Neustar, Inc. All Rights Reserved 2

THE TELEPHONE CONSUMER PROTECTION ACT (TCPA)

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#16PACE TCPA Lawsuits on the Rise Damages of $500 – $1,500 per unsolicited call, text or facsimile Lawsuits can cost tens of millions and are on the rise Consumers on the offensive! Copyright © 2015 Neustar, Inc. All Rights Reserved 5 Copyright © 2016 Neustar, Inc. All Rights Reserved $45M – AT&T Mobility $34M – Chase Bank $32M – Bank of America $14.5M – Wells Fargo $5.4M – Kaiser Permanente $4.5M – Best Buy NOTABLE RECENT CASE LAW AND CLASS ACTION SUITS 2015 $73M – Capital One $15M – Life Time Fitness $11M – Walgreens $10.2M – JPMorgan Chase $10M – Abercrombie & Hollister $6.25M – Anthem BCBS 2014 $45M – AT&T Mobility $34M – Chase Bank $32M – Bank of America $14.5M – Wells Fargo $5.35M – Kaiser Permanente $4.5M – Best Buy 2012 $47M – Jiffy Lube $24M – Sallie Mae 2013 $16.5M – Papa John’s $10M – Steve Madden 1,102 Lawsuits 1,904 Lawsuits 2,558 Lawsuits 3,710 Lawsuits * Litigation Numbers Source: WebRecon, LLC

#16PACE FCC 2015 Declaratory Ruling KEY POINTS Definition of “Called Party” – (i.e. reassigned phones) –‘Intended recipient’ of a call/text does not matter –TCPA requires consent of current subscriber (i.e. current owner/subscriber) –Autodialing a wrong or reassigned phone number poses risk Revocation of Consent –Prior express consent required to autodial/text a consumer with information –A consumer may revoke consent at any time, through any reasonable means Definition of An Autodialer –Basic function is to dial a lot of numbers quickly without human intervention –Equipment that “has the capacity to store or produce, and dial random or sequential numbers, even if it is not presently used for that purpose” Limited Exemptions –Limited exceptions for time-sensitive financial/healthcare calls or emergencies Changes Afoot? Copyright © 2016 Neustar, Inc. All Rights Reserved 6

MANAGING YOUR TCPA RISK

#16PACE Key Questions for Your Business 1.What percent of your customer phones are landline vs. wireless 2.What % of customer phone numbers have been reassigned or were entered incorrectly? 3.How frequently should you monitor for reassigned phones? 4.How are you following up with your consumers? Autodialing? Texting? 5.How are you storing consent? Copyright © 2016 Neustar, Inc. All Rights Reserved 8

#16PACE Why consent is not enough: Reassigned numbers pose risk Reassigned phone numbers pose a TCPA risk for callers/texters. 45 Million people changed their phone number last year When a phone number is reassigned, the consent on file is no longer valid. Consent is needed from the new subscriber/customary user of that phone number. The FCC identified a number of industry best practices including the use of third- party data providers to identify reassigned phone numbers. Copyright © 2016 Neustar, Inc. All Rights Reserved 9 “Callers have a number of options available that, over time, may permit them to learn of reassigned numbers. For example, at least one database can help determine whether a number has been reassigned.” The FCC Order Referencing Neustar Services

#16PACE Best Practices to Help Mitigate TCPA Risk Copyright © 2016 Neustar, Inc. All Rights Reserved 10 Proper Consent Ensure you capture and maintain consent 1 Identify Phone Type  Landline vs. Wireless vs. VOIP  Correct for Porting 3 Confirm Subscriber  Ensure phone not reassigned  Repeat verification every 30 days 4 Auto-Dialer? Understand the dialing technologies within your organization 2

#16PACE Key Questions When assessing Vendors 1.Be very skeptical of any vendor that talks about 100% coverage. 2.Understand limitations to vendor’s approach of identifying reassigned phone numbers. Every approach has limitations. 3.Like minded references are important. Not all companies manage TCPA the same. 4.Understand service response times and the impact on your operations? 5.Understand how the vendor asses OTT VoIP’s, Porting, incorrectly initially submitted data, family plans and business phones 6.Test, test and always test Copyright © 2016 Neustar, Inc. All Rights Reserved 11

Copyright © 2016 Neustar, Inc. All Rights Reserved IDENTIFYING REASSIGNED PHONE NUMBERS

#16PACE Dialing Strategy: What are Companies Doing Today? 13 Source: SourceMedia Research, April 2015 online survey of 211 respondents from CCR subscriber base Exclusively manual dial mobile phones Mix of manual dialing and auto-dialing mobile phones, when there is consumer consent on mobiles Exclusively auto-dial mobile phones Copyright © 2016 Neustar, Inc. All Rights Reserved

#16PACE Similar issues 14 Copyright © 2016 Neustar, Inc. All Rights Reserved Financial ServicesCollectionsHealthcareRetail MarketingCSPsUtilities

#16PACE Copyright © 2016 Neustar, Inc. All Rights Reserved 15 NEUSTAR: SELECTED BY TELCOS AS IDENTITY PARTNER » Power 85% of ALL US CallerID (~4 billion calls/day) » Deliver Daily Directory Assistance in the US » Deliver Daily Port Data » Provide Market Share Analytics to Telcos We Help Manage Identity in the Telecommunications Industry We are measured one record at a time - billions of times a day » Verify 1.4 Billion Commerce Transactions Every Day » Help Large Corporations Manage TCPA Risk And Provide Phone Verification Services

#16PACE Neustar offers multiple solutions Neustar has been verifying phone data for 15+ years First solution provider in the TCPA market. Heard feedback on challenges using disconnect and in- service data from one of the largest banks in world. Came up with Identity Centric Approach: Is this phone associated with a consumer…Most widely used product in the market. Minimize risk, while also maximizing RPC. We also have new product in market… Copyright © 2016 Neustar, Inc. All Rights Reserved 16

#16PACE CLIENT CASE STUDY: Collections Agency NEUSTAR ANALYSIS OF CALL DATA SHOWED: 44% of phones were bad – reassigned or inactive  Identified and removed to minimize risk and inefficiency 55% of good phones accounted for 92% of revenue  Increase collection rates by %  Increase right-party contacts by 60% Copyright © 2016 Neustar, Inc. All Rights Reserved 17 20

#16PACE Integrated Solution Heat Map Copyright © 2016 Neustar, Inc. All Rights Reserved 18 Neustar Verification VerifiedNeutralMismatchTotal Phone Activity – ACTIVE More than 12 Months 8.00%7.22%1.85%5.40% Months 9.15%1.96%0.81%4.96% Months 6.01%4.00%0.92%3.52% Months 7.67%3.97%0.80%4.20% Up to 3 Months 2.79%1.23%1.04%1.84% Up to 2 Months 0.93%1.47%0.00%0.58% Up to 1 Month 2.15%1.63%0.49%1.44% Phone Activity - INACTIVE Up to 1 Month 3.87%2.43%2.34%2.93% Up to 2 Months 1.54%0.75%1.44%1.40% Up to 3 Months 2.91%0.00%0.17%0.87% Months 3.67%1.16%0.08%1.39% Months 0.83%4.23%0.26%0.87% Months 0.00% 0.21%0.13% No Activity in 12 Months 0.25%0.00%0.14%0.15% Grand Total 4.97%3.42%0.68%2.26%  Table shows cross-tab of Neustar Verification and Phone Activity using CLIENT RPC dispositions  Each cell represents the % of Right-Party-Contacts in that combination of Verification and Phone Activity Current RPC Rate

#16PACE Copyright © 2015 Neustar, Inc. All Rights Reserved 19 % of Total Phones Total # of RPC’s RPC Rate % of Total RPC’s Dials/RPC $ Collected Per Dial BEST 20%5607.5%66.9%13$38.46 BETTER 14%1182.3%14.1%43$11.49 BAD 21%891.5%10.6%67$7.50 WORST 44%700.4%8.4%250$2.00 CURRENT 100%8372.3%100%44$ % Bad Numbers Current RPC RateCurrent $ Collected Per Dial 92% of Revenue in 55% of Portfolio Distilling Phone Ownership & Phone Activity

#16PACE Request from the Market – Continue to Help Increase Operational Efficiency Copyright © 2016 Neustar, Inc. All Rights Reserved 20 MOST ACTIVE TIME PER WEEK DAY BY A PHONE TNMondayTuesdayWednesdayThursdayFridaySaturdaySunday XXXX12pm – 2pm4pm – 6pm10am – 12pm2pm – 4pm6pm – 8pm1pm – 3pm2pm – 4pm XXXX4pm – 6pm6pm – 8pm1pm – 3pm2pm – 4pm NA XXXX10am – 12pm1pm – 3pm12pm – 2pm6pm – 8pm4pm – 6pm6pm – 8pm1pm – 3pm XXXXNA10am – 12pm 12pm – 2pm1pm – 3pm12pm – 2pm6pm – 8pm Times are Greenwich Mean Time (GMT).

#16PACE In Summary Must use Authoritative, Accurate phone intelligence that is updated Daily Verify consumer Ownership, Reassignments & Phone Type Leverage Activity Insights from phone Prioritize Best phone numbers; Cut the Bad phone numbers START THE CONVERSATION! Copyright © 2016 Neustar, Inc. All Rights Reserved 21 OPERATIONAL EFFICIENCY & TCPA RISK MITIGATION

#16PACE Copyright © 2016 Neustar, Inc. All Rights Reserved 22 Tom Nowaczyk Call Neustar: Visit Neustar: Questions?