Telephone Consumer Protection Act Compliance Policy

This Telephone Consumer Protection Act Compliance Policy (the "Policy") sets forth the requirements ReferralExchange, including its employees, contractors, and agents (together, "ReferralExchange") must adhere to when making telephone calls directed to consumers. If you have any questions about this Policy, please contact Tom Monaghan.

Any interested party may request a copy of this Policy directly from a call center agent or by emailing: support@realestateagents.com, with the Subject Line: Request for DNC Policy.

Policy Statement

The Telephone Consumer Protection Act ("TCPA") granted the Federal Communications Commission ("FCC") authority to develop rules related to telemarketing and the use of automated telephone dialers. Specifically, the TCPA directed the FCC to initiate rulemaking "concerning the need to protect residential telephone subscribers' privacy rights to avoid receiving telemarketing calls to which they object."

The TCPA explicitly included the authority to create "a single national database to compile a list of telephone numbers of residential subscribers who object to receiving telemarketing calls." To that end, the FCC has issued regulations ("DNC Rules") establishing a national "Do-Not-Call" registry ("DNC Registry"). Those regulations impose financial penalties on commercial telemarketers that call phone numbers on the DNC Registry. For those numbers not on the registry, the regulations set a maximum rate on the number of abandoned calls and require telemarketers to transmit caller ID information. The FCC has expanded coverage of the national Do-Not-Call registry to include banks, insurance companies, credit unions, savings associations, and other financial institutions. Further, the Federal Trade Commission's ("FTC") calling regulations, codified in its Telemarketing Sales Rule ("TSR") parallel the FCC regulations and apply to all business entities, including third parties acting as agent or on behalf of a financial institution. Individual states have similar laws and regulations governing the making of telephone calls.

ReferralExchange is required to adhere to all of the provisions of the above-referenced laws and regulations through the implementation of this Policy.

General Provisions

ReferralExchange will abide by the following requirements:

• ReferralExchange will not initiate a telephone call to a residential telephone subscriber who has registered his or her telephone number on the national DNC Registry.
• In addition to the national DNC Registry, consumers can opt out of receiving future communications from ReferralExchange by either (a) responding "STOP" to a text message received from ReferralExchange, or (b) clicking the Your Privacy Choices link at the bottom of our website and selecting your preferences (an "Internal DNC Request"). All Internal DNC Requests will be processed upon receipt and placed upon ReferralExchange's internal Do-Not-Call list within ten (10) days. Each Internal DNC Request will remain on ReferralExchange's internal Do-Not-Call list for five (5) years from the date the number was placed on the list.
• ReferralExchange will not place telephone calls to a residential telephone number before 8:00 a.m. or after 9:00 p.m. Monday thru Saturday (local time at the residential telephone number location), or before 9:00 a.m. or after 9:00 p.m. on Sunday (local time at the residential telephone number location). In states where stricter time of date restrictions have been enacted, ReferralExchange will adhere to the more stringent requirements.
• ReferralExchange will obtain prior expressed written consent prior to making any (1) calls using an automatic telephone dialing system, or (2) prerecorded calls or texts.
• ReferralExchange will send no more than three (3) communications to a consumer within a 24-hour period. In states where stricter time of communication frequency restrictions have been enacted, ReferralExchange will adhere to the more stringent requirements.
• ReferralExchange will adhere to all caller-ID requirements, including by (1) not blocking caller-ID information on outbound calls, and (2) transmitting accurate caller-ID information on outbound calls.
• ReferralExchange will not dial any telephone number in order to determine whether the line is a facsimile ("fax") or voice line. ReferralExchange will not use fax machines, computers, or other devices to send unsolicited advertisements.

Compliance

Staff Training

ReferralExchange requires participating agents involved in the placement of outbound telephone calls to undergo training regarding the requirements outlined in this Policy. After being trained in the procedures and the content of this Policy, participating agents will be required to sign an acknowledgement that they understand the Policy.

Internal/External Audit Review

This Policy requires that appropriate and timely tests, audits, and evaluations be conducted to ensure ReferralExchange is in compliance with TCPA regulations. ReferralExchange has designated the Compliance Department to conduct periodic audit reviews of ReferralExchange's compliance efforts.

Document Retention

ReferralExchange will retain copies of all records required by the TCPA and evidencing compliance with this Policy, including, but not limited to, all evidence of customer consent, revocation of customer consent, and customer do-not-call requests, for a period of five (5) years.

Other Policies

Please refer to the following Policies for additional relevant information:

• Agent Terms of Use
• Privacy Policy
• Consumer Terms of Use