CUNA, NAFCU, and other organizations met with the Federal Communications Commission (FCC) several times in recent weeks on the Telephone Consumer Protection Act (TCPA) and TRACED Act rulemakings. The participants discussed FCC’s ongoing proceedings regarding revocation of consent under the TCPA and certain proposals regarding call blocking, labeling and notification of blocking under the TRACED Act.

The organizations reiterated their strong support for actions to remove bad actors and illegal traffic from the calling network while ensuring legitimate, often critical calls from credit unions and other entities can be completed.

The organizations also reiterated their filed comments on:

• The TCPA revocation of consent rulemaking, that businesses not be compelled to opt customers out of broader categories than intended; and that the proposal would create “unreasonable, impracticable” standards with a 24-hour limit to honor revocation requests.
• The importance of enforcing the TRACED Act’s requirement that entities provide effective and transparent redress for erroneous blocking and the FCC’s rules implementing those provisions.
• Require entities blocking calls based on analytics to use SIP Code 608 and/or SIP Code 603+ once tested,
• Extending current notification and redress requirements for blocked calls to mislabeled calls.

CUNA, NAFCU, the American Bankers Association, ACA International, American Financial Services Association, Consumer Bankers Association, Mortgage Bankers Association, and National Council of Higher Education Resources filed ex parte letters memorializing these meetings with the FCC for the record.