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.