Cold Call Compliance

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May 1, 2009 6:01 pm

I am wanting to make cold calls. My compliance said it would not be allowed us I submitted a script to be approved and stated the following on EVERY CALL:



Hello, Mr. Jones, this is John Doe. I am a registered representative and investment advisor representative with Blue Sky Investment Services. My office is located at 1290 W. Central Ave. Anywhere, Idaho 99882. My ofice number is 209-998-4455. We are a member of FINRA and SIPC.



May I mail you some information on investments?

----------------------------

Just curious if anyone else is also required to state your name, title, name of firm, office address, office phone number and FINRA/SIPC info. before speaking to the person?



May 1, 2009 6:18 pm
Stonewall:

I am wanting to make cold calls. My compliance said it would not be allowed us I submitted a script to be approved and stated the following on EVERY CALL:

Hello, Mr. Jones, this is John Doe. I am a registered representative and investment advisor representative with Blue Sky Investment Services. My office is located at 1290 W. Central Ave. Anywhere, Idaho 99882. My ofice number is 209-998-4455. We are a member of FINRA and SIPC.

May I mail you some information on investments?
----------------------------
Just curious if anyone else is also required to state your name, title, name of firm, office address, office phone number and FINRA/SIPC info. before speaking to the person?

 
I'm at an indy firm and we don't have those requirements.  I wouldn't be surprised if most people hang up even before you finish. 
 
My requirement: just don't call anybody on the DNC list.  What kind of firm are you? (wire, bank?)
May 2, 2009 9:26 am

That's what happens when lawyers write a prospecting script.

 
The simple solution is to call businesses-DNC doesn't apply.
 
Most of us give that info in a converstational way anyway. The law says that we must promptly give this info. It doesn't say it's got to be the first thing out of our mouths.
 
It's not our fault if the caller hangs up before all that info can be given.
 
I'm not going to give you advice on how to proceed here beyond this: Next time you have a marketing question don't take it to the anti-business department.
 
 
 
 
 
 
 
May 2, 2009 10:07 am
Stonewall:

I am wanting to make cold calls. My compliance said it would not be allowed us I submitted a script to be approved and stated the following on EVERY CALL:

Hello, Mr. Jones, this is John Doe. I am a registered representative and investment advisor representative with Blue Sky Investment Services. My office is located at 1290 W. Central Ave. Anywhere, Idaho 99882. My ofice number is 209-998-4455. We are a member of FINRA and SIPC.

May I mail you some information on investments?
----------------------------
Just curious if anyone else is also required to state your name, title, name of firm, office address, office phone number and FINRA/SIPC info. before speaking to the person?



 
That is the most idiotic script I've ever heard of.
 
Are you sharing the same office space as your compliance officer?
 
You should make your calls from home and speak to people NORMALLY instead of doing something so STUPID.
 
I make up my own calling scripts all the time.  I don't DISTRIBUTE them to other agents (they're MY property) and I don't say anything STUPID in my scripts.  ("Stupid is as stupid does.")
 
This is one of the problems with being securities licensed... they can restrict your freedom of speech and expression "because it isn't approved".
May 2, 2009 11:09 am

By the way, Stonewall, the fact that the call is cold is irrelevant, you still have to give that information if it is a referral.  I believe what is legally required is your name and the name of your firm.

 
Bondguy, what does the DNC list have to do with this?  If he calls businesses, the information still needs to be given.
May 2, 2009 11:03 pm


[/quote]



 
That is the most idiotic script I've ever heard of.
 
Are you sharing the same office space as your compliance officer?
 
You should make your calls from home and speak to people NORMALLY instead of doing something so STUPID.
 
I make up my own calling scripts all the time.  I don't DISTRIBUTE them to other agents (they're MY property) and I don't say anything STUPID in my scripts.  ("Stupid is as stupid does.")
 
This is one of the problems with being securities licensed... they can restrict your freedom of speech and expression "because it isn't approved".[/quote]
 
Ominous, I completely agree with you.  To HAVE TO SAY that first before anything else is completely stupid, bottomline.  Whoever wrote that can't honestly believe that the script would work in getting prospects.  Some firms "discourage" reps from cold calling, so that might be their way of restricting it. 
May 3, 2009 9:41 am
anonymous:
 Bondguy, what does the DNC list have to do with this?  If he calls businesses, the information still needs to be given.
 
His script is taken word for word  from DNC contact rule.
May 3, 2009 10:30 am
army13A:


Ominous, I completely agree with you.  To HAVE TO SAY that first before anything else is completely stupid, bottomline.  Whoever wrote that can't honestly believe that the script would work in getting prospects.  Some firms "discourage" reps from cold calling, so that might be their way of restricting it. 
 
So make your calls somewhere else where they can't hear you "violate" their rules.
 
Your home office is a great place to make cold-calls because:
1)  You're calling from a residential number.  (You can get a packet8 or Vonage number for this purpose.)
2)  Your name will show up on caller ID instead of your firm name.
3)  EVEN IF they say they're on the DNC list, what proof do they have that you're calling from your FIRM?  You're calling from home with a residential number.
4)  Your compliance junkies won't be able to exercise their little power trip over you because they can't hear you from their office when you're at home.
5)  You'll be more comfortable at home and you won't have to embarrass yourself in front of your peers while making your calls (even though your peers are doing NOTHING of the sort).
 
All you need to say is:  Hi, I'm [insert your name here] from XYZ firm here in [city location].  If they wanted to file a complaint, they have enough information to find you.
May 3, 2009 2:53 pm

Just pick up the phone and introduce yourself to the person you are calling.  Is compliance sitting in your office or cube?  Dont use compliance or the DNC as reasons not to call people, just get on the phone.

May 5, 2009 12:01 pm

Stonewall - I agree that script intro is idiotic. Why did Compliance reject the script? I suspect there is more to the story. If I were you, I wouldn't take the advice of using an unapproved script. All it takes is for you to inadvertantly call a regulator at home or a complainer and your arse will get in trouble. A script is sales lit and more than likely your firm has a policy (which is based on FINRA rule 2210) that says it must be submitted to Compliance. If FINRA finds out you used an unapproved script, you, your BOM and your firm will get dinged. Find out exactly why your script was rejected. Then ask your BOM to talk to the supervisor of the Compliance person that reviewed it to help you find a way to make it work.     

May 5, 2009 6:17 pm

Thanks for all of the input. I work for an independent B/D and I do have a home office. I want to be compliant, but, as has been mentioned, I am finding that it's basically ridiculous to have someone pick up the phone and say 'hello' and then give them a 50 second intro. before I state why I am calling. Just wanted to see if anyone else is required to do the same. It's a dilemma because the reality is, in my opinion, if you want to make money you simply have to get on the phone and get on the phone often - there is no other way (sorry to those who think they can make it on referrals alone).

May 7, 2009 3:50 pm

To be practical, you can probably work the script to say "hi I'm john doe, registered representative from XYZ firm's miami office." then go into your script. If they show an interest, then at the end of the call you can ask then for their email address and send them the info you're pitching and your more detailed contact info.