As part of a joint trades group representing important
financial services, health care and other industries, CUNA conducted outreach
to Federal Communications Commission (“FCC” or “Commission”) staff regarding
the Commission’s proposed Telephone Consumer Protection Act of 1991 (“TCPA”)
robocalling regulations and requests for comments regarding current TCPA
exemptions. The FCC’s recent TCPA notices were required by the Telephone
Robocall Abuse Criminal Enforcement and Deterrence Act of 2019 (TRACED Act).
The joint trades emphasized that the FCC’s record clearly
demonstrates the need for telephone providers to prevent erroneous call
blocking and labeling of legitimate calls and to require quick and effective
resolution of such errors. Examples of credit unions facing these problems were
discussed, and the group reiterated the need for a 24-hour time-frame for
resolution of such problems.
During the call, the joint trades also advocated against the
imposition of restrictions on the existing exemption for informational calls
placed to residential telephone numbers and against confusing and costly “opt
out” requirements or arbitrary limits on non-marketing informational calls.
Additional details can be found in the required notices for
these ex parte communications which are posted here and here.