HOW TO BE PROFITABLE IN THE COLLECTION INDUSTRY, WITHOUT AI VOICES.
FCC ruling bans robocalls with cloned voices generated by AI

HOW TO BE PROFITABLE IN THE COLLECTION INDUSTRY, WITHOUT AI VOICES.

That's an AI-generated picture to describe an earthquake and remind us of the far-reaching implications of the FCC's decision to outlaw AI-generated voices for any unsolicited calls. Although it was targeted at the telemarketing industry, poorer consumer attorneys are probably celebrating this gift.

Generative AI and cutting-edge AI voice technology have been the talk of the industry for well over a year. Companies like Floatbot.ai and Skit.ai have shown the industry how large language models and artificial voice offer timely solutions to labor shortages, compliance requirements, and consumer-thirst for self-service.

On February 8th the Federal Communications Commission made a ruling that recognized calls made with AI-generated voices were “artificial” under the Telephone Consumer Protection Act (TCPA). The ruling made voice cloning technology illegal, giving "State Attorneys General across the country new tools to go after bad actors" and yes, another reason for consumer attorneys to target the collection industry. What does the collection industry do? Traditionally we have reacted to these announcements, seeking the options of the industry's own expert legal minds. Understanding the details, nuances and exceptions within the ruling will take several months. That's time that the industry does not have, to slow down the many initiatives that are desperately needed. What do we do?


HOW ARE WE USING ARTIFICIAL VOICE IN COLLECTIONS?

Cloning voices and pictures of nature

That's an AI-generated picture of a horse, and a reminder that AI is everywhere. In collections, we are making outbound calls using "digital agents" with AI-voices that cannot be differentiated from humans.

Computers have "talked to us" for over 20 years. It was called text- to-speech (TTS) and some of the defining advances made over the years were :

  • 1984, the IBM Speech Viewer became one of the first TTS systems to offer a range of voices and speaking styles.
  • In 1999, Microsoft released technology to read screens and say its content on Windows computers.
  • In 2007, the Apple iPhone's TTS read text messages and other content aloud.
  • Artificial intelligence (AI) was used after 2010, to produce more natural-sounding speech. In 2011, Google released a TTS API offering broad use cases.
  • Today, AI is used in speech technology to simulate intonation, male or female voices, different accents and voices that could sound old or young.

It would be accurate to say that 20 years ago, TTS used natural language processing (NLP). However, there was little or no machine learning that allowed products to accurately comprehend human language and respond to it. Those products were a part of the operating systems (like Windows) and were never described as AI voices.

In the last two years "Conversational AI" has become the most talked-about technology in collections, thanks to ChatGPT and Open AI. The technology was advancing by leaps and bounds and the collection industry needed a problem to solve and providing 24/7 customer service using intelligent chatbots was that problem. Initially this was a self-service option where the consumer initiated the contact, and was greeted by or transferred to a chatbot.

For many years, we had utilized outbound dialer technology with IVR (Interactive Voice Response) technology. These were primarily deployed in payment portals where consumers could pick from a list of options and make payments using the keypad on a phone.

As the AI voice technology matured and the industry needed more, we decided to put robots on outbound calls. Chatbots have replaced conventional IVR technology that worked with dialers. ChatGPT and Generative AI had been integrated with Conversational AI products to elevate a lagging collection industry to new levels of technology adoption. There had been nothing but positive feedback from the vendors and agencies.

But what just happened?

?

THE EARTHQUAKE

Paul Carpenter, a New Orleans-based magician, claims to have been hired by the Democrats to create an AI-generated deepfake recording of Joe Biden that was used before the New Hampshire primary on January 23rd. This was one of the factors that forced the FCC to ban AI-generated robocalls.

With potential lawsuits, it is arguably more important for the ARM industry to act quickly than to overthink or analyze the recent events. We don't have many choices, and we believe that our options are limited to the following.

First, an important disclaimer - Anything we say must not be construed as legal advice and you should check with your attorney before making any of the changes we have recommended.

  • If you make outbound calls and the consumer is greeted with high quality speech (which is most likely an AI-generated voice), stop this process immediately.
  • Go back to using a dialer to launch outbound calls. Make sure you are using conventional IVR options with older TTS technology.Make sure you are talking to the right consumer, make it clear that the next option is a chatbot and not a real person, and ask the consumer if they would like to "talk to your intelligent chatbot". If the consumer wishes to do that, you can connect them to an AI voice because you only used an AI-generated voice after the consumer was given that option and selected it.
  • The FCC states that the ruling "restricts the making of telemarketing calls and the use of automatic telephone dialing systems and artificial or prerecorded voice messages". If you use a dialer and have a machine say anything or play a message when the call is answered by an answering machine, you are using automatic telephone dialing systems and artificial or prerecorded voice messages. Assuming this requirement is exactly as stated, does it mean that launching a call with an ATDS and having a machine (IVR) say "This is an attempt to collect a debt and this call may be recorded for quality assurance purposes", is no longer permitted? This is an area that will probably have to be clarified by the FCC, sooner than later.
  • The FCC also says that "Under FCC rules, it also requires telemarketers to obtain prior express written consent from consumers before robocalling them. This Declaratory Ruling ensures AI-generated voices in calls are also held to those same standards".If this applies to debt collection (and we must assume that), this seems to imply that robocalls using artificial or AI-generated voices are permitted with prior express consent (we believe that 'written' consent is not required for collections).

These changes are practical and proactive responses to the new FCC rules. They are not difficult to implement if you control your technology stack that includes your collection software, dialer and chatbots.

Quantrax's intelligent chatbots can be engaged via a link to a cell phone, a web link, your web site, direct drop voice mail, or a phone call. The voice has always been traditional TTS or AWS's speech engine that is not advertised as having AI voices - We have a very limited choice of a few voices. We considered powerful speech synthesis and Generative AI products from companies like 11ElevenLabs, but did not go down that path. Clearly, that was a good bet.

In closing, for those of you who had invested in outbound products that use AI-generated voices, you will be concerned about a short-term loss of productivity due to the FCC's ruling. It has always been Quantrax's position that Conversational AI and chatbots offer very limited use of AI within the collection industry. While the use of Generative AI will enhance a consumer's self-service experience, it has no impact on consumers who do not want to be contacted, but whose accounts need to be worked and managed economically.

Compare Conversational AI to collection software that is undisputedly the brains of any collection operation, managing operations, financial transactions, 3rd party integrations, people, and compliance requirements. could the FCC's bombshell be the incentive the industry needed to revisit collection software? We recently wrote a paper on this greatly under-reported area. You can read that paper here.


Quantrax Corporation is a technology company that created an intelligent collection platform over 25 years ago. They believe that the ARM industry has been poorly served by collection technology that has not evolved or kept up with the great potential of computing power, or challenging industry changes. Self-funded, Quantrax has continued to successfully develop and deploy technology that offers modern solutions to old problems.

www.quantrax.com – (301) 657-2084



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