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CUNA Regulatory Comment Call

February 25, 2000

EXECUTIVE SUMMARY

• The Department of Commerce (DOC), on behalf of the Subgroup on Legal Barriers to Electronic Commerce, requests public comments and suggestions concerning policies laws or regulations that need to be adapted in order to eliminate barriers to and promote electronic commerce. These comments are due by March 17, 2000. Please submit comments to CUNA by March 10, 2000 by e-mail to mprofit@cuna.com or by fax to Mary Dunn or Michelle Profit at (202) 371-8240.



• The DOC believes barriers may involve requirements that particular types of transactions be conducted on paper or in person, or that records be maintained or provided in written form. They may also include regulatory, statutory or licensing requirements, or technical standards and other policies that hinder electronic commerce or otherwise require business or transactions to be conducted in a way that discriminates against the online environment.



• Comments may focus on transactions among businesses and between consumers and businesses. Transactions between government agencies and the public are excluded from this review.



• Comments are requested on how barriers could be removed while ensuring that equivalent consumer protections are available in e-commerce and traditional commerce.



• This inquiry excludes comments on tax laws or regulations and consumer protection regulations subject to current rulemaking by the Federal Reserve, including regulations B, E, M, Z and DD. Also excluded are issues addressed by the Government Paperwork Elimination Act and privacy laws.

QUESTIONS

• Does any federal agency-administered law or regulation impose an impediment to the conduct by electronic means of commercial transactions between you or your firm, company or organization and any other non-government party or parties? (Please cite or identify the law or regulation)?

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• What is the extent of the impediment? Does it bar, slow down or increase costs for e-commerce?

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• What is the nature of the impediment (e.g., is it a written requirement)?

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• Can you provide information as to the costs that are associated with the impediment?

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• What do you understand to be the reason for imposing the requirement that causes the impediment?

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• Can you suggest alternative ways, other than through the requirement that causes the impediment, by which the agency could achieve the goal of the requirements? Examples that work in other contexts would be helpful.

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• Can you suggest ways in which the requirement can be modified to remove or reduce the impediment while continuing to provide consumer protections for electronic transactions that are equivalent to those that exist for offline transactions.

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• Have you encountered impediments to electronic commerce that stem from licensing requirements, technical standards, codes, or other policies? If yes, what are they and how could they be removed?

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