CUNA supports the establishment of a centralized, Federal Communications Commission (FCC) supervised database to which all voice providers should be required to report reassigned numbers, it told the FCC in a letter sent Monday. CUNA responded to the FCC’s notice of inquiry about robocalling and re-assigned phone numbers.
“CUNA believes that a national database under the auspices of the Commission and operated by a Commission-designated and supervised entity would best guarantee accurate and timely information on reassigned numbers,” the letter reads. “CUNA concurs with the Commission’s assessment that such an approach would allow the agency to oversee quality, appropriately limit access and preserve and protect the data.
This model has previously been used by the FCC and Federal Trade Commission in creating and maintaining the national “Do Not Call” registry.
Specifically, CUNA recommends:
In addition, CUNA recommends the FCC creates a workable safe harbor from liability for callers that use the re-assigned database number, noting that this would be particularly appropriate for credit unions.
“Credit union communications with their member-owners are mostly informational in nature, often providing critically important financial information, and can include information related to the governance of the credit union,” the letter reads. “Credit unions do not target non-members or third parties with such communications. Credit unions should not have to fear potential liability if they have demonstrably used the reassigned number database yet mistakenly call a reassigned number.”
CUNA also urged the FCC to promptly revise its current re-assigned numbers rules.