2. The Laws of Outbound Calling: Enhancing Marketing Effectively and Legally Presented by: Michael F. Smith, Ken Paley, Matt Wilson, and Dana Smith

3. W ELCOME & I NTRODUCTIONS Mr. Michael F. Smith- McAfee&Taft Mr. Kenneth Paley- Episcopal Retirement Homes Mrs. Dana Smith- Murdock Mr. Matt Wilson- Murdock What about you? Mr. Michael F. Smith- McAfee&Taft Mr. Kenneth Paley- Episcopal Retirement Homes Mrs. Dana Smith- Murdock Mr. Matt Wilson- Murdock What about you?

4. S ENIOR L IVING T ODAY

5. W HAT IS YOUR E XPERIENCE ? Influx of senior living/senior care providers? Greater number of options for seniors- day services, home health, companionship services? Seniors are waiting longer for Independent Living and Assisted Living? Limited sales and marketing resources? Influx of senior living/senior care providers? Greater number of options for seniors- day services, home health, companionship services? Seniors are waiting longer for Independent Living and Assisted Living? Limited sales and marketing resources?

6. S ENIOR L IVING T ODAY More competitors +More options +Seniors waiting longer +No dramatic change in resources ($ or people) =Necessity for increased sales efforts and activity, more productivity, greater efficiency More competitors +More options +Seniors waiting longer +No dramatic change in resources ($ or people) =Necessity for increased sales efforts and activity, more productivity, greater efficiency

7. W HY DO WE NEED TO MAKE C ONTACT ? Stay top-of-mind with prospects and their families Keep a pulse on prospects’ situations, life changes, changes in needs or circumstances Establish and maintain a relationship Move a prospect toward moving in Stay top-of-mind with prospects and their families Keep a pulse on prospects’ situations, life changes, changes in needs or circumstances Establish and maintain a relationship Move a prospect toward moving in

8. P RESENTATION D ISCUSSION T OPICS 1.Overview of the FCC (Federal Communication Commission) and TCPA (Telephone Consumer Protection Act) 2.Developing and Executing a Successful Outbound Calling Campaign 3.Case study: Episcopal Retirement Communities’ Successes 1.Overview of the FCC (Federal Communication Commission) and TCPA (Telephone Consumer Protection Act) 2.Developing and Executing a Successful Outbound Calling Campaign 3.Case study: Episcopal Retirement Communities’ Successes

9. The Telephone Consumer Protection Act of 1991 Legislative History How the TCPA affects ALL of us Is it Constitutional? The FCC’s Jurisdiction Does it Pre-empt More Stringent State Laws? What’s Prohibited Penalties for Violations The Plaintiffs’ Bar’s Efforts to Expand TCPA Liability Best Practices Legislative History How the TCPA affects ALL of us Is it Constitutional? The FCC’s Jurisdiction Does it Pre-empt More Stringent State Laws? What’s Prohibited Penalties for Violations The Plaintiffs’ Bar’s Efforts to Expand TCPA Liability Best Practices

10. O VERVIEW : THE FCC AND TCPA

11. The TCPA – Legislative History Congress passed the TCPA in response to consumer concerns and complaints about the growing number of unsolicited telephone marketing calls to their homes and the increasing use of automated dialers and prerecorded messages. 137 Cong. Rec. 18123 (1991) (noting that the TCPA was intended to “target[] calls that are the source of consumer complaints – telemarketing calls placed to the home”). Congress passed the TCPA in response to consumer concerns and complaints about the growing number of unsolicited telephone marketing calls to their homes and the increasing use of automated dialers and prerecorded messages. 137 Cong. Rec. 18123 (1991) (noting that the TCPA was intended to “target[] calls that are the source of consumer complaints – telemarketing calls placed to the home”).

12. The TCPA – Legislative History When Congress passed the TCPA in 1991, it delegated the do-not-call rules to the FCC. But the Federal Trade Commission, not the FCC, established the National Do Not Call Registry. When Congress passed the TCPA in 1991, it delegated the do-not-call rules to the FCC. But the Federal Trade Commission, not the FCC, established the National Do Not Call Registry.

13. The TCPA – Legislative History Mims v. Arrow Fin. Servs., LLC, 132 S. Ct. 740, 745 (2012) (citing legislative history noting that “[u]nrestricted telemarketing... can be an intrusive invasion of privacy” 102 Cong. Rec. S18317 (daily ed. November 26, 1991) (statement of Sen. Presler) (explaining how sequential dialing has sometimes blocked hospital lines and created substantial hazards). Mims v. Arrow Fin. Servs., LLC, 132 S. Ct. 740, 745 (2012) (citing legislative history noting that “[u]nrestricted telemarketing... can be an intrusive invasion of privacy” 102 Cong. Rec. S18317 (daily ed. November 26, 1991) (statement of Sen. Presler) (explaining how sequential dialing has sometimes blocked hospital lines and created substantial hazards).

14. Who… US? 1.Do you have a lead database that contains phone numbers? 2.Do you purchase lead lists with phone numbers? 3.Do you have a sales/marketing person/team responsible for initiating outbound phone calls? 4.Do you actively fundraise? 5.Do you have a “marketing” line item in your operating budget? 6.Are you using a telemarketing firm? 7.Are you a for-profit organization? 1.Do you have a lead database that contains phone numbers? 2.Do you purchase lead lists with phone numbers? 3.Do you have a sales/marketing person/team responsible for initiating outbound phone calls? 4.Do you actively fundraise? 5.Do you have a “marketing” line item in your operating budget? 6.Are you using a telemarketing firm? 7.Are you a for-profit organization?

15. The TCPA Affects ALL Senior Living and Care Providers Not just “telemarketing” calls are regulated by the TCPA: our sales teams’ outbound sales/marketing promotional calls, too The TCPA handles Non-profit and For-profit groups differently Whether calling from your lead database or from a purchased lead list, UNDERSTAND the regulations and successfully work within them Not just “telemarketing” calls are regulated by the TCPA: our sales teams’ outbound sales/marketing promotional calls, too The TCPA handles Non-profit and For-profit groups differently Whether calling from your lead database or from a purchased lead list, UNDERSTAND the regulations and successfully work within them

16. Understand the Terminology… Telephone solicitation: The term “telephone solicitation” is defined as any call or message made “for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services, which is transmitted to any person.” (“messages that are part of an overall marketing campaign to encourage the purchase of goods or services or that describe the commercial availability or quality of any goods or services, are ‘advertisements’ as defined by the TCPA”). Telephone solicitation: The term “telephone solicitation” is defined as any call or message made “for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services, which is transmitted to any person.” (“messages that are part of an overall marketing campaign to encourage the purchase of goods or services or that describe the commercial availability or quality of any goods or services, are ‘advertisements’ as defined by the TCPA”).

17. Understand the Terminology… Prior express written consent: Prior express written consent: The phrase “prior express written consent” is defined as “an agreement, in writing, bearing the signature of the person called that clearly authorizes the seller to deliver or cause to be delivered to the person called advertisements or telemarketing messages using an automatic telephone dialing system or an artificial or prerecorded voice, and the telephone number to which the signatory authorizes such advertisements or telemarketing messages to be delivered.”

18. Understand the Terminology… Do-Not-Call Registry: The do-not-call registry is a national database of persons who do not wish to receive telephone solicitations that is maintained by the Federal Government. The TCPA regulates compliance of the do-not-call registry and explicitly forbids telephone solicitation calls to phone numbers on the do-not-call without prior express written consent.

19. The TCPA – Is It Constitutional? The TCPA's constitutionality was challenged by telemarketers soon after it was enacted. – Moser v. FCC, 46 F.3d 970 (9th Cir. 1995) cert. denied, 515 U.S. 1161 (1995) – Destination Ventures Ltd. v. FCC, 46 F.3d 54 (9th Cir. 1995), Effectively settled this issue finding the restrictions in the TCPA were constitutional. The TCPA's constitutionality was challenged by telemarketers soon after it was enacted. – Moser v. FCC, 46 F.3d 970 (9th Cir. 1995) cert. denied, 515 U.S. 1161 (1995) – Destination Ventures Ltd. v. FCC, 46 F.3d 54 (9th Cir. 1995), Effectively settled this issue finding the restrictions in the TCPA were constitutional.

20. The TCPA – The FCC’s Jurisdiction Congress entrusted the interpretation and enforcement of the TCPA to the FCC. – Charvat v. EchoStar Satellite, LLC, 630 F.3d 459, 466 (6th Cir. 2010) (FCC has substantial authority to implement the TCPA) – Clark v. Time Warner Cable, 523 F.3d 1110, 1114 (9th Cir. 2008) (noting that the FCC has “quasi-legislative powers” and is actively involved in the administration of federal communications statutes). Congress entrusted the interpretation and enforcement of the TCPA to the FCC. – Charvat v. EchoStar Satellite, LLC, 630 F.3d 459, 466 (6th Cir. 2010) (FCC has substantial authority to implement the TCPA) – Clark v. Time Warner Cable, 523 F.3d 1110, 1114 (9th Cir. 2008) (noting that the FCC has “quasi-legislative powers” and is actively involved in the administration of federal communications statutes).

21. The TCPA – Does it Pre- empt More Stringent State Laws? The TCPA does not preempt states from imposing more restrictive intrastate requirements on telephone solicitations. Charvat v. GVN Michigan, Inc., 561 F.3d 623 (6th Cir. 2009). What have the states done in this regard? Get a legal opinion for your home state. The TCPA does not preempt states from imposing more restrictive intrastate requirements on telephone solicitations. Charvat v. GVN Michigan, Inc., 561 F.3d 623 (6th Cir. 2009). What have the states done in this regard? Get a legal opinion for your home state.

22. The TCPA – What’s Prohibited? As of October 16, 2013, the FCC regulations enforcing the TCPA require callers to obtain “prior express written consent” before making marketing calls to wireless numbers. See 47 C.F.R. § 64.1200(a)(2). The 2013 regulations also dropped the “established business relationship exemption” for pre-recorded telemarketing calls to residential landlines. As of October 16, 2013, the FCC regulations enforcing the TCPA require callers to obtain “prior express written consent” before making marketing calls to wireless numbers. See 47 C.F.R. § 64.1200(a)(2). The 2013 regulations also dropped the “established business relationship exemption” for pre-recorded telemarketing calls to residential landlines.

23. The TCPA – What’s Prohibited? The phrase automatic telephone dialing system (ATDS) is defined as “equipment which has the capacity--(A) to store or produce telephone numbers to be called, using a random or sequential number generator; and (B) to dial such numbers.” 47 U.S.C. § 227(a)(1). The focus is on the “capacity” of the equipment to do so and not whether the caller actually used that capacity. Satterfield v. Simon & Schuster, Inc., 569 F.3d 946, 951 (9th Cir. 2009). The phrase automatic telephone dialing system (ATDS) is defined as “equipment which has the capacity--(A) to store or produce telephone numbers to be called, using a random or sequential number generator; and (B) to dial such numbers.” 47 U.S.C. § 227(a)(1). The focus is on the “capacity” of the equipment to do so and not whether the caller actually used that capacity. Satterfield v. Simon & Schuster, Inc., 569 F.3d 946, 951 (9th Cir. 2009).

24. The TCPA – What’s Prohibited? Requires solicitors maintain a company-specific “do- not-call” (DNC) list of consumers who asked not to be called; the DNC request must be honored for 5 years. Requires solicitors honor the National Do Not Call Registry. Requires solicitors maintain a company-specific “do- not-call” (DNC) list of consumers who asked not to be called; the DNC request must be honored for 5 years. Requires solicitors honor the National Do Not Call Registry.

25. The TCPA – What’s Prohibited? Requires solicitors provide their name, the name of the person or entity on whose behalf the call is being made, and a telephone number or address at which that person or entity may be contacted. Prohibits solicitations to residences that use an artificial voice or a recording. Requires solicitors provide their name, the name of the person or entity on whose behalf the call is being made, and a telephone number or address at which that person or entity may be contacted. Prohibits solicitations to residences that use an artificial voice or a recording.

26. The TCPA – What’s Prohibited? Prohibits any call made using automated telephone equipment or an artificial or prerecorded voice to an emergency line (e.g., "911"), a hospital emergency number, a physician's office, a hospital/health care facility/elderly room, a cellular telephone, or any service for which the recipient is charged for the call. Prohibits autodialed calls that engage two or more lines of a multi-line business. Prohibits unsolicited advertising faxes. Prohibits any call made using automated telephone equipment or an artificial or prerecorded voice to an emergency line (e.g., "911"), a hospital emergency number, a physician's office, a hospital/health care facility/elderly room, a cellular telephone, or any service for which the recipient is charged for the call. Prohibits autodialed calls that engage two or more lines of a multi-line business. Prohibits unsolicited advertising faxes.

27. The TCPA – What’s Prohibited? The TCPA applies to “calls” that are text messages. Satterfield v. Simon & Schuster, Inc., 569 F.3d 946, 951-54 (9th Cir. 2009). The CAN-SPAM Act made a minor amendment to the TCPA to explicitly apply the TCPA to calls and faxes originating from outside the U.S. The TCPA applies to “calls” that are text messages. Satterfield v. Simon & Schuster, Inc., 569 F.3d 946, 951-54 (9th Cir. 2009). The CAN-SPAM Act made a minor amendment to the TCPA to explicitly apply the TCPA to calls and faxes originating from outside the U.S.

28. The TCPA – What’s Prohibited? Internal Do-Not-Call List: All companies that initiate telemarketing calls or telephone solicitations to residential or wireless subscribers must have “instituted procedures for maintaining a list of persons who request not to receive telemarketing calls.” 47 C.F.R. § 64.1200(d) and (e). Those procedures must meeting the following minimum standards: 1)it must be a written policy available upon demand; 2)personnel must be informed and trained in the existence and use of the do-not-call list; 3)if an entity receives a request from a subscriber not to receive calls, that entity must record the request and place the subscribers telephone number and name if given on the do-not-call list (and such request must be honored within a reasonable time (and within 30 days); 4)entity making a call for telemarketing purposes must provide the called party with the name of the individual caller, the name of the person or entity on whose behalf the call is being made, and a telephone number or address at which the person or entity may be contacted (and that contact number cannot be a 900 number); 5)entity must maintain record of consumer’s do-not-call request and that request must be honored for 5 years. Internal Do-Not-Call List: All companies that initiate telemarketing calls or telephone solicitations to residential or wireless subscribers must have “instituted procedures for maintaining a list of persons who request not to receive telemarketing calls.” 47 C.F.R. § 64.1200(d) and (e). Those procedures must meeting the following minimum standards: 1)it must be a written policy available upon demand; 2)personnel must be informed and trained in the existence and use of the do-not-call list; 3)if an entity receives a request from a subscriber not to receive calls, that entity must record the request and place the subscribers telephone number and name if given on the do-not-call list (and such request must be honored within a reasonable time (and within 30 days); 4)entity making a call for telemarketing purposes must provide the called party with the name of the individual caller, the name of the person or entity on whose behalf the call is being made, and a telephone number or address at which the person or entity may be contacted (and that contact number cannot be a 900 number); 5)entity must maintain record of consumer’s do-not-call request and that request must be honored for 5 years.

29. The TCPA – Live v. Autodialed Calls Live calls are not as heavily restricted. Autodialed calls and prerecorded voice messaging are TCPA’s primary targets. Live calls are not as heavily restricted. Autodialed calls and prerecorded voice messaging are TCPA’s primary targets.

30. The TCPA – Penalties for Violations Uncapped damages of $500 per unlawful call, with damages trebled ($1,500 per call) for “knowing and/or willful violations” of the TCPA. 47 U.S.C. §§ 227(b)(3)(B).

31. The Future of TCPA Litigation Senior Living: A Unique kind of Not-for-profit FCC amendments to the TCPA regulations? Senior Living: A Unique kind of Not-for-profit FCC amendments to the TCPA regulations?

32. Efforts to Expand TCPA Liability After several years, enterprising attorneys came to realize that the TCPA could be a powerful class action weapon, sometimes yielding astronomical sums in damages. The courts are divided whether in favor of or opposed to class actions being brought under the TCPA. After several years, enterprising attorneys came to realize that the TCPA could be a powerful class action weapon, sometimes yielding astronomical sums in damages. The courts are divided whether in favor of or opposed to class actions being brought under the TCPA.

33. Efforts to Expand TCPA Liability The new push is in the reassigned number context. Courts have ruled that a caller is subject to liability under the TCPA where the caller makes a call to a number for which it had consent but the number had been deactivated and reassigned to another person. Soppet v. Enhanced Recovery Co., LLC, 679 F.3d 637, 643 (7th Cir. 2012). The new push is in the reassigned number context. Courts have ruled that a caller is subject to liability under the TCPA where the caller makes a call to a number for which it had consent but the number had been deactivated and reassigned to another person. Soppet v. Enhanced Recovery Co., LLC, 679 F.3d 637, 643 (7th Cir. 2012).

34. D EVELOPING AND E XECUTING A S UCCESSFUL O UTBOUND C ALLING C AMPAIGN

35. S ENIOR L IVING T ODAY

37. How Many Calls are Sales People Making Before they Give Up ? Zero Calls !

38. Effective Calling Campaigns Time management Blocks of uninterrupted time Call at the right time on the right days Script calls: make calls with one purpose Effective Telephone skills Engage experienced senior living tele-contact firm Time management Blocks of uninterrupted time Call at the right time on the right days Script calls: make calls with one purpose Effective Telephone skills Engage experienced senior living tele-contact firm

39. Effective Calling Campaigns Time Management: – Call leads with whom there is no extensive relationship (conversations are shorter!) – Set reasonable goals for a calling campaign. If calling 500 numbers, assume for 2.5-3 hours of calling each day over 10 days – How do you eat an elephant…? Break up the 2.5 hours into two shorter timeframes – Remain focused on the reason of the call: have short, purposeful calls Time Management: – Call leads with whom there is no extensive relationship (conversations are shorter!) – Set reasonable goals for a calling campaign. If calling 500 numbers, assume for 2.5-3 hours of calling each day over 10 days – How do you eat an elephant…? Break up the 2.5 hours into two shorter timeframes – Remain focused on the reason of the call: have short, purposeful calls

40. Effective Calling Campaigns Blocks of uninterrupted time: – Closed door (“please don’t interrupt”) – No email – Forwarded phone – No appointments – Set other team members’ expectations as to availability Blocks of uninterrupted time: – Closed door (“please don’t interrupt”) – No email – Forwarded phone – No appointments – Set other team members’ expectations as to availability

41. Effective Calling Campaigns Call at the right times on the right days – Inclement weather days will yield more success – Mid-week yields more success than Fridays and Mondays – Call after 10:00am and before 4:30pm Call at the right times on the right days – Inclement weather days will yield more success – Mid-week yields more success than Fridays and Mondays – Call after 10:00am and before 4:30pm

42. Effective Calling Campaigns Script calls – Succinct – Limited to factual and necessary conversation – Moves the call in the right direction – Ask the question you called to ask (IE, Appointment? Event? Received mailing? Referrals?) – End the call politely Script calls – Succinct – Limited to factual and necessary conversation – Moves the call in the right direction – Ask the question you called to ask (IE, Appointment? Event? Received mailing? Referrals?) – End the call politely

43. Effective Calling Campaigns Effective telephone skills – Use a headset – Use senior-appropriate pace – Speak clearly, pause – Sincerity – Repeat prospect’s name – Provide contact information Effective telephone skills – Use a headset – Use senior-appropriate pace – Speak clearly, pause – Sincerity – Repeat prospect’s name – Provide contact information

44. Best Practices Calling times: set specific calling times for your home time zone; keep in mind- cell phones make this complicated. Have an appropriate scripted standard response when someone responds to a call by saying they’re number is “on the do-not-call”- include an apology. Maintain a list (utilizing your lead database functionality) of those who specifically mention the “do-not-call” list or specifically ask you not to call again. Calling times: set specific calling times for your home time zone; keep in mind- cell phones make this complicated. Have an appropriate scripted standard response when someone responds to a call by saying they’re number is “on the do-not-call”- include an apology. Maintain a list (utilizing your lead database functionality) of those who specifically mention the “do-not-call” list or specifically ask you not to call again.

45. Three-Pronged Approach 1.Event – Plan to host an event – Set date, time, theme – Secure appropriate space 2.Direct Mail Invitation – Develop quality invitation or postcard to promote event – Compelling with appealing event information – Consistent with brand standards – Mail to lead list to receive 2-3 weeks prior to event 3.Tele-contact campaign – Call invitation recipients – Ensure that they received the invitation – Personally invite them to attend the event 1.Event – Plan to host an event – Set date, time, theme – Secure appropriate space 2.Direct Mail Invitation – Develop quality invitation or postcard to promote event – Compelling with appealing event information – Consistent with brand standards – Mail to lead list to receive 2-3 weeks prior to event 3.Tele-contact campaign – Call invitation recipients – Ensure that they received the invitation – Personally invite them to attend the event

46. Why this Three-Pronged Approach? 1.Increases event attendance (gets more prospects on campus) 2.Helps event and direct mail dollars go further 3.Provides one more person-to-person point of contact: one more touch 4.Puts the community name in front of the prospect two different ways: visually and verbally 5.Qualifies leads to improves the health of the database 1.Increases event attendance (gets more prospects on campus) 2.Helps event and direct mail dollars go further 3.Provides one more person-to-person point of contact: one more touch 4.Puts the community name in front of the prospect two different ways: visually and verbally 5.Qualifies leads to improves the health of the database

47. C ASE S TUDIES : E PISCOPAL R ETIREMENT H OMES ’ M ARJORIE P. L EE & D EUPREE H OUSE

48. Marjorie P. Lee, Episcopal Retirement Homes

49. Tele-contact Case Study Background (Marjorie P. Lee): CCRC in Cincinnati, OH. Unit Mix—90 IL, 37 AL, 9 MC and 60 SN beds. Desired to increase attendance at an on-site event. Murdock was engaged to contact the lead base and secure reservations to the event. Background (Marjorie P. Lee): CCRC in Cincinnati, OH. Unit Mix—90 IL, 37 AL, 9 MC and 60 SN beds. Desired to increase attendance at an on-site event. Murdock was engaged to contact the lead base and secure reservations to the event.

50. Tele-contact Case Study Challenge: Scheduled informational educational event No invitations mailed Event attendance driven by personal telephone invitation only Challenge: Scheduled informational educational event No invitations mailed Event attendance driven by personal telephone invitation only

51. Tele-contact Case Study Implementation: 357-number list of the community’s leads. Script developed with the help of the sales and marketing staff. Over a two-day period, the entire lead list was called. Implementation: 357-number list of the community’s leads. Script developed with the help of the sales and marketing staff. Over a two-day period, the entire lead list was called.

52. Tele-contact Case Study Results: – 25 prospects (7.0%) RSVP’d to the event with the Tele-contact agent. – 4 prospects (1.1%) scheduled a personal appointment with an on-site sales professional after speaking with the Tele-contact agent. – 43 prospects (12.0% ) remained uncalled, as event capacity had been reached. – 86 prospects (24.1%) were qualified as uninterested – 7 prospects (1.9%) moved, wrong number, do-not-call, or died. Results: – 25 prospects (7.0%) RSVP’d to the event with the Tele-contact agent. – 4 prospects (1.1%) scheduled a personal appointment with an on-site sales professional after speaking with the Tele-contact agent. – 43 prospects (12.0% ) remained uncalled, as event capacity had been reached. – 86 prospects (24.1%) were qualified as uninterested – 7 prospects (1.9%) moved, wrong number, do-not-call, or died.

53. Deupree House, Episcopal Retirement Homes

54. Tele-contact Case Study Background (Deupree House): CCRC in Cincinnati, Ohio. Unit Mix - 85 Independent Living, 60 Assisted Living, 24 Skilled. Client desired to increase attendance at a Valentine’s event. Murdock was engaged to contact the lead base and secure reservations to the event. Background (Deupree House): CCRC in Cincinnati, Ohio. Unit Mix - 85 Independent Living, 60 Assisted Living, 24 Skilled. Client desired to increase attendance at a Valentine’s event. Murdock was engaged to contact the lead base and secure reservations to the event.

55. Tele-contact Case Study Challenge: Highly-anticipated Valentines Day event Two weeks from event: lower-than-desired event reservations Mailing delay occurred with invitations Challenge: Highly-anticipated Valentines Day event Two weeks from event: lower-than-desired event reservations Mailing delay occurred with invitations

56. Tele-contact Case Study Implementation: 380-number list of community’s leads Script developed with the help of the sales and marketing staff Personal invitation extended to Holiday event Over a three-day period, the entire lead list was called Implementation: 380-number list of community’s leads Script developed with the help of the sales and marketing staff Personal invitation extended to Holiday event Over a three-day period, the entire lead list was called

57. Tele-contact Case Study Results: – 42 (11.0 %) RSVP’d to the event with the Tele-contact agent. – 2 prospects (.5%) could not attend the Valentine’s Day event but requested additional information about the community. – 79 voicemails (20.8%) were left requesting a returned call to the community. – 160 prospects (42.1%) were qualified as uninterested – 30 prospects (7.9%) were qualified as moved, wrong number, do-not- call, or died. Results: – 42 (11.0 %) RSVP’d to the event with the Tele-contact agent. – 2 prospects (.5%) could not attend the Valentine’s Day event but requested additional information about the community. – 79 voicemails (20.8%) were left requesting a returned call to the community. – 160 prospects (42.1%) were qualified as uninterested – 30 prospects (7.9%) were qualified as moved, wrong number, do-not- call, or died.

58. Tele-Contact Cost Analysis *Direct mail and event costs estimated. Actual direct mail and event costs may vary.