Attention All Agents
Important Compliance Reminder: Telemarketing, Foreign Call Centers & Consumer Protection
Please Review the Telemarketing Sales Rules Below
Recent incidents in the insurance industry involving foreign call centers selling leads and spoofing caller IDs continue to raise serious compliance concerns and consumer protection risks.
We are issuing this urgent reminder to reinforce your responsibilities under the Telemarketing Sales Rule (TSR), the Telephone Consumer Protection Act (TCPA), and applicable state laws.
Foreign Call Centers & Lead Vendors
It has come to our attention that certain offshore call centers not affiliated with GTL are attempting to sell leads or impersonate consumers to solicit policy information. These tactics often violate federal Do Not Call regulations, federal and state consumer privacy protections, and may involve identity spoofing, theft or fraud of both client and Agent’s identities and information.
For example, we have recently heard of instances in the industry where foreign call centers are attempting to recruit agents to sell on their behalf. Partnering with such unknown call centers has resulted in stolen agent identifies, fraudulent sales made on the agent’s behalf, and, in some cases, unsuspecting agents are left with large debit balances owed to insurance companies.
If GTL becomes aware of any agent, agency, or lead vendor using deceptive practices—including falsifying caller ID or misrepresenting GTL—the company will take immediate action, including contract termination and reporting to state and federal regulators.
Telemarketing Sales Rules Refresher
Please remember:
- Automated calls, texts, or robocalls require explicit consumer consent with clear disclosures.
- All outbound calls must comply with Do Not Call lists unless a valid Established Business Relationship (EBR) or written consent exists.
- Leads from third parties do not establish an EBR.
- You must retain written consent records for at least 7 years.
- Automated calls, texts, or robocalls require explicit consumer consent with clear disclosures.
Protecting Consumer Identity
Spoofed calls and phishing attempts are increasing throughout the industry. Agents must be vigilant
- Never disclose policy numbers or personal data unless caller identity is verified.
- Report suspicious calls relative to your relationship or customers with GTL immediately to GTL’s compliance teamproviding specific details of the incident. Direct calls to 800-323-6907 or email agency@gtlic.com
Compliance Is Not Optional
Violations of the TSR or TCPA may jeopardize your appointment with GTL. We are committed to protecting consumers and maintaining the integrity of our brand.
If you have questions or need clarification, please contact us at 800-323-6907 or email agency@gtlic.com
Thank you for your continued commitment to ethical and compliant sales practices. Below is a reminder of the Telemarketing Sales Rules. Failure to comply with the Telemarketing Sales Rule (TSR) and the Telephone Consumer Protection Act (TCPA) may jeopardize your appointment with GTL.
The below Telemarketing Sales Rules (“Rules”) summarize the Telemarketing Sales Rule (“TSR”), the Telephone Consumer Protection Act (“TCPA”) and state telemarketing laws. These rules and laws govern your marketing efforts whenever you use the telephone to solicit insurance on behalf of Guarantee Trust Life Insurance Company (“GTL”).
Telemarketing
These Rules summarize the provisions of the TSR (16 CFR Part 310), TCPA (47 U.S.C. section 227) and any state telemarketing laws including, but not limited to the following:
1. Any solicitation to sell insurance using the telephone or any other equipment that automates communication functions (including Zoom, text and fax) is considered Telemarketing.
2. Unless an Exception applies as described in 3 below, all Outbound Calls (calls initiated by an agent, telemarketer or lead service) for Telemarketing must:
a. Obtain a Subscription Account Number (SAN); and
b. Confirm that the number being called is not on any Do Not Call list.
3. Exceptions – Outbound Calls can be made, even if the number is on the Do Not Call list if:
a. There is an Established Business Relationship (“EBR”) between the caller and the consumer. An EBR exists when the consumer purchased a product within the last 18 months or the consumer inquired about a product within the last 3 months. Leads received from a third party do not establish an EBR. However, a telemarketer calling on behalf of GTL may be an EBR if such consumer purchased a GTL product as indicated above; or
b. The consumer provides explicit written permission to call. Such permission may be an electronic signature or a check-off box indicating the consumer wants the telemarketer to call. The authorization to call must include the consumer’s telephone number. You must retain a copy of the written permission to call for at least seven (7) years after the communication is made.
4. During any Telemarketing call You must communicate the following:
a. The total cost of the policy;
b. Any exclusions or restrictions;
c. Refund/cancel terms, including any Free Look period;
d. That GTL is the seller
e. State the purpose of the call is to sell insurance;
f. Indicate the type of insurance.
5. Call Prohibitions –
a. Abusive calling patterns such as repeated calls, threats, profanity
b. Calling other than between the hours of 8:00am-9:00pm (as reflected in the time zone of the consumer, not the seller)
c. Call abandonment (consumer must be connected within two seconds of answering the call.
d. Failure to transmit the Caller I.D.
6. In addition to the above, unless express written consent of the consumer is received, you may not contact the consumer through any automated communications method for telemarketing purposes. In order to give consent, a consumer first needs to receive a clear and conspicuous disclosure stating they will receive future automated and/or pre-recorded communications, they need to designate the phone number to be contacted, and they must be told such consent is not a condition of purchase. These Rules summarize the provisions of the TSR (16 CFR Part 310), TCPA (47 U.S.C. section 227) and any state telemarketing laws including, but not limited to the following:
1. Any solicitation to sell insurance using the telephone or any other equipment that automates communication functions (including Zoom, text and fax) is considered Telemarketing.
2. Unless an Exception applies as described in 3 below, all Outbound Calls (calls initiated by an agent, telemarketer or lead service) for Telemarketing must:
a. Obtain a Subscription Account Number (SAN); and
b. Confirm that the number being called is not on any Do Not Call list.
3. Exceptions – Outbound Calls can be made, even if the number is on the Do Not Call list if:
a. There is an Established Business Relationship (“EBR”) between the caller and the consumer. An EBR exists when the consumer purchased a product within the last 18 months or the consumer inquired about a product within the last 3 months. Leads received from a third party do not establish an EBR. However, a telemarketer calling on behalf of GTL may be an EBR if such consumer purchased a GTL product as indicated above; or
b. The consumer provides explicit written permission to call. Such permission may be an electronic signature or a check-off box indicating the consumer wants the telemarketer to call. The authorization to call must include the consumer’s telephone number. You must retain a copy of the written permission to call for at least seven (7) years after the communication is made.
4. During any Telemarketing call You must communicate the following:
a. The total cost of the policy;
b. Any exclusions or restrictions;
c. Refund/cancel terms, including any Free Look period;
d. That GTL is the seller
e. State the purpose of the call is to sell insurance;
f. Indicate the type of insurance.
5. Call Prohibitions –
a. Abusive calling patterns such as repeated calls, threats, profanity
b. Calling other than between the hours of 8:00am-9:00pm (as reflected in the time zone of the consumer, not the seller)
c. Call abandonment (consumer must be connected within two seconds of answering the call.
d. Failure to transmit the Caller I.D.
6. In addition to the above, unless express written consent of the consumer is received, you may not contact the consumer through any automated communications method for telemarketing purposes. In order to give consent, a consumer first needs to receive a clear and conspicuous disclosure stating they will receive future automated and/or pre-recorded communications, they need to designate the phone number to be contacted, and they must be told such consent is not a condition of purchase.
Failure to comply with the Telemarketing Sales Rule (TSR) and the Telephone Consumer Protection Act (TCPA) may jeopardize your appointment with GTL.
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