CUNA supports the creation of a robust, comprehensive reassigned numbers database, it wrote to the Federal Communications Commission Thursday. CUNA has raised the issue of reassigned numbers, as part of other concerns with the Telephone Consumer Protection Act (TCPA) with the FCC, efforts that resulted in the FCC issuing a public notice requesting comments.

“Despite the limited, informational nature of their communications, credit unions nonetheless find themselves the target of frivolous TCPA litigation.  A recurring concern is reassigned numbers,” the letter reads. “Like telephone consumers generally, credit union members frequently change their contact numbers that were provided to the credit union, and do not necessarily think to immediately inform the credit union of the change.  The credit union may then call the number to provide information without any knowledge that the number has been reassigned, potentially exposing it and its member-owners to liability.”

Specifically, CUNA supports the establishment of a “single, centralized and comprehensive database to which all providers with access to telephone numbers should report reassigned numbers.”

CUNA believes the FCC should also:

• Ensure the database is affordable and as easy to use as possible. CUNA suggests a fee structure similar to the national “Do Not Call” list, for which users pay a per-area code dee, with a cap on the maximum cost; and
• Create a safe harbor for callers that utilize the database, structured similarly to the safe harbor established by the national “Do Not Call” list in which a caller demonstrates that it checks numbers against the database as part of its routine business practices.