NAFCU comment letter re: TCPA prior express consent
WASHINGTON, DC (March 9, 2017) — Good afternoon,
Attached please find NAFCU Regulatory Affairs Counsel Ann Kossachev’s letter to the Federal Communications Commission (FCC) regarding the Telephone Consumer Protection Act (TCPA).
In the letter, Kossachev wrote, since the FCC’s 2015 Declaratory Ruling and Order (the Order) interpreting the Telephone Consumer Protection Act (TCPA), credit unions have been forced into the precarious position of deciding between contacting their members and running the risk of violating the TCPA or not contacting their members, thereby withholding vital notifications and updates regarding their existing accounts. NAFCU requests the FCC deny the Petition and carefully consider any changes to the interpretation of “prior express consent” so as to not create more regulatory obstacles for credit unions that are simply trying to serve their members as effectively as possible.
“NAFCU asks that the FCC build in an exemption for credit unions. At the very least, the FCC should further study the credit union industry to better understand the member-first approach of credit unions nationwide and realize how the TCPA and the FCC’s 2015 Order have harmed, instead of helped, consumers.”
If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.
National Association of Federally-Insured Credit Unions
The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to www.nafcu.org or @NAFCU on Twitter.