Your Mass Arb Completion Stack Already Solves the Class Action Claims Rate Problem. You Just Haven't Pointed It There Yet.

Here is a number that should bother you: the FTC's median claims rate in consumer class actions is 9 percent.

Nine percent. Meaning 91 out of every 100 class members who are entitled to money never file a claim. The notice goes out, the postcard lands, the email hits spam, and the settlement fund sits there until the check-cashing deadline passes and the residual gets cy pres'd to a nonprofit nobody picked.

If you run mass arbitration, you already know what this looks like. You have seen the same decay curve. You built infrastructure to fight it. And you are probably not using that infrastructure on the class action side of your practice.

That is the opportunity most firms are sitting on right now.

The Claims Rate Is a Completion Rate by Another Name

In mass arb, you model a release threshold (usually 75 to 85 percent of signed claimants executing their release and closing statement). You know that hitting that number is not about sending one notice. It is about building a persistent outreach cadence: SMS, email, AI voice, follow-up, follow-up, follow-up. The claimant who ignores week one signs in week twelve.

A class action claims rate is the same math wearing a different hat. The settlement is approved. The notice plan runs. And then you wait for class members to file claims. The difference is that nobody treats the claims period like a conversion funnel. Legacy administrators send a notice, maybe a reminder, and call it done.

The result? Multi-touch outreach campaigns in mass arb routinely push completion past 80 percent. Single-touch notice campaigns in class actions sit at 9 percent. The gap is not about the claimants. It is about the infrastructure.

Why Legacy Administrators Don't Fix This

Traditional claims administrators (Epiq, Simpluris, Angeion, the big shops) were built for notice adequacy, not claims maximization. Their business model is optimized around satisfying Rule 23 notice requirements and surviving fairness hearings. They send direct mail at $0.08 per piece, run a call center at per-minute rates, publish a settlement website, and file a declaration saying notice was adequate.

That is a compliance function. It is not an engagement function.

The incentive structure tells the story. Most administrators bill on a time-and-materials or flat-fee basis that does not change whether 4 percent or 40 percent of the class files claims. Some even benefit from lower claims rates because fewer claims means less processing work against the same admin fee. There is no economic reason for them to send a seventh SMS to a class member who ignored the first six.

Compare that to a completion-oriented model. At GroupSettle, we charge $9.99 per fully signed claimant, stepping to $11.99 on every signed claimant if the matter hits its release threshold. Every additional claimant who signs is revenue. Every one who doesn't is money we left on the table. The incentive runs in the same direction as the firm's.

That alignment is what doubles claims rates. Not better notice language. Not fancier websites. Aligned economics plus persistent outreach.

The Infrastructure You Already Own

If you are running mass arb campaigns today, you have already built (or bought) the pieces that fix a 9 percent claims rate:

• Native document signing. Class members need to submit claim forms, verify identity, and sometimes execute releases. You already have e-signature with audit trails.
• SMS and email delivery at scale. You already send multi-touch outreach sequences to thousands of claimants. A class action claims campaign is the same workflow with a different document at the end.
• AI-powered inquiry handling. Class members have the same questions arbitration claimants do: "Is this real?" "What do I need to submit?" "When do I get paid?" An AI super agent that handles 80 percent of those inquiries (which is what ours does) works identically in both contexts.
• Engagement tracking and re-engagement triggers. You already model response curves and trigger follow-up sequences based on claimant behavior. Apply that logic to claims filing and you are running a conversion funnel, not a notice campaign.

The point is not that you need new technology. The point is that you already have the technology and you are only deploying it on half your docket.

What Multi-Touch Does to a Claims Rate

The FTC data on claims rates is instructive not for the 9 percent median but for the variance. Some settlements hit 30, 40, even 60 percent claims rates. The common thread in the high performers is not the settlement amount or the class size. It is the number of touches.

Direct notice (email to a known class member) reliably outperforms publication notice by 5x or more. Adding SMS follow-up to email pushes response rates further. Adding a second and third SMS at staggered intervals pushes them further still. The curve looks almost identical to the mass arb completion curve: steep early gains, a plateau, then a slow grind where each additional touch costs more but moves the number.

A legacy administrator running one email and one postcard is operating on the flat part of the curve before it even starts to climb. A completion-oriented administrator running 8 to 12 touches across SMS, email, and AI voice is operating where the real volume lives.

The math is simple. If your settlement fund is $5 million and your claims rate is 9 percent, $4.55 million goes unclaimed. Push that rate to 25 percent with persistent outreach and you put an additional $800,000 into class members' hands. The admin cost of those extra touches is a fraction of the recovered value.

MDL 3162 and the Scrutiny That's Coming

There is a regulatory tailwind here, too. MDL 3162 and related judicial scrutiny of rebate-style settlements (where the defendant gets credit for unclaimed funds) are pushing courts to look harder at actual claims rates. Judges are starting to ask why a $50 million settlement resulted in $3 million in actual payouts. The answer, increasingly, is that the notice plan was designed for adequacy, not for engagement.

Firms that can walk into a fairness hearing and show a multi-touch claims campaign with documented response curves, channel-level engagement data, and a completion rate north of 20 percent are going to have an easier time getting settlements approved. Firms that show a single postcard and a 6 percent claims rate are going to face harder questions.

This is not speculation. It is the direction the case law is moving. And the firms that are already running completion infrastructure for mass arb are the ones best positioned to meet that standard on the class action side.

The Second Revenue Line

Here is what this looks like as a business decision. You have already invested in the completion stack for your mass arb practice. The marginal cost of deploying that same stack on a class action claims campaign is close to zero. You are not building new technology. You are not hiring new vendors. You are pointing existing infrastructure at a different document type.

The revenue upside is real. Higher claims rates mean more money distributed to class members, which means higher fee awards to class counsel (courts look at actual benefit delivered, not theoretical fund size). It also means fewer cy pres distributions, fewer uncashed-check residuals, and fewer escheatment headaches down the line.

And it means you walk into your next settlement negotiation with a credible answer to the question every defense counsel asks: "How do we know the class will actually claim this money?"

You know because you have the data from your mass arb campaigns showing what persistent outreach does to a response curve. That is not a pitch. It is a track record.

The Takeaway

A 9 percent claims rate is not a fact of life. It is an infrastructure failure. The same infrastructure that pushes mass arb completion past 80 percent can push class action claims rates past 25 percent. The firms that see this first will own two revenue lines with one tech stack.

Stop treating your completion infrastructure as a mass-arb-only asset. It is the most underdeployed tool in your practice.

If you want to see how the completion math translates from mass arb to class action claims administration, that is exactly the kind of modeling we run for firms. Reach out to Kasia at (813) 737-7025 or visit classaction.groupsettle.com.

Harry Hedaya is the founder of Send It By Text, the native document signing, SMS, and email platform behind GroupSettle's mass arbitration completion stack. Their AI super agent handles over 80% of claimant inquiries on its own, which lifts engagement rates further. He works with plaintiff firms running live mass arb campaigns.