For those of you that specialize in assisting individual taxpayers instead of businesses, you may have noticed some recent upsets in the leads world. Due to increasing regulation and pressure from the Federal Trade Commission, it’s getting harder and harder to access individual taxpayers through the telephone. One of the largest list brokers in the country recently quit offering tax liens at all due to these issues.
Here at Tax Liens HQ, we are still offering 1040 tax lien leads, but we recently made the decision to no longer offer phone numbers on those leads, and I’d like to explain why that is and what your options are instead.
If you are calling individual consumers at all, the FTC requires that you have what is called a SAN number. This is a subscription number to the national Do Not Call list registry. Even if you purchase phone numbers from a list broker, you are still required to have your own SAN number and remove numbers from your list that are on the Do Not Call List, even if the list broker says they do it for you.
Subscribing to the Do Not Call list is not inconsequential. A SAN number that covers the entire United States costs around $15,000. However, this is nothing compared to the FTC fines for telemarketing to consumers without a SAN number. The fines can be as high as $11,000 PER PHONE CALL.
So what does this have to do with us no longer offering phone numbers? The FTC has recently begun to hold list brokers accountable for the actions of their customers. There is pending civil litigation around this issue, since depending on who you ask, the law doesn’t allow for this, but the FTC is doing it anyway. Since we are a fairly small “mom and pop” business, we simply cannot afford the liability exposure if the FTC were to make an issue with us providing phone numbers to our customers and our customers failed to obtain SAN numbers and comply with the Do Not Call List rules and the Telemarketing Sales Rule. So, long story short, our attorney told us to stop.
So where does this leave you for obtaining phone numbers? Check out various phone append services that exist online, and pick one that meets your needs.
Alternatively, have you considered direct mail? For the cost of a SAN number for the entire United States, you could pay postage and printing for between 60,000 and 70,000 postcards to go out. At a 1% response rate, you should be able to sell nearly half a million dollars worth of tax resolution services through direct mail and taking inbound phone calls, not to mention hundreds of thousands of dollars worth of tax prep, Quickbooks, and other accounting and tax services.
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