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and to take approximately eight new DMP inquiries on an average
business day.
Petitioner’s training materials inform its anticipated
future employees that its goal is to provide them with the
necessary resources to ensure the success of its clients on DMPs.
Petitioner may adopt a bonus structure for its call center
employees “in accordance with industry norms.” Mr. Dennis made
clear that petitioner would identify and service DMP candidates,
screen third-party vendors that offer appropriate products and
services, and expand the DMP portfolio before referring its
customers to such vendors. Mr. Dennis also acknowledged that
petitioner might receive referral and marketing fees for
generating leads for outside vendors.
Mr. Dennis stated that as petitioner’s DMP operation
“evolves and becomes more viable,” petitioner will begin
screening vendors that offer services that complement
petitioner’s “growing Portfolio of DMP Customers”. Petitioner
will expose its customers to “various Products and Services -
that will complement their short- and long-term financial goals”
such as mortgage and insurance products. Petitioner might
receive referral fees for marketing these products and services
to its potential customers.
Mr. Dennis stated that petitioner also plans to provide
information to callers on credit report analysis, properly
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Last modified: March 27, 2008