CUNA letter to FCC calls for autodialer definition and consent

June 15, 2018


CONTACT: Lauren Williams – CUNA Communications; (202) 626-7642;

Washington, D.C. (June 14, 2018) – Credit Union National Association (CUNA) is seeking clarity on several issues under the Telephone Consumer Protection Act (TCPA) to help reduce confusion for credit unions trying to comply with the law. In a comment letter filed to the Federal Communications Commission (FCC) Wednesday, CUNA petitions for the agency to define key statutory terms and identify methods to revoke consent.  

The FCC issued a public notice following a court ruling that overturned parts of TCPA interpretation, which creates several compliance and liability burdens for credit unions attempting to report important account information to their members.  

“Defining key statutory terms such as an automatic telephone dialing systems (ATDS) and ‘called party’ and identifying reasonable methods to revoke consent consistent with the TCPA’s language and intent will substantially reduce uncertainty and help mitigate the onslaught of frivolous TCPA litigation. The commission should also use this opportunity to update antiquated distinctions between wireless and wireline calls when companies make informational calls to their customers or members, as requested in CUNA’s petition for declaratory ruling.” 

The comment letter specifically urges the FCC to:  

  • Revise its reassigned number framework by defining the called party as the intended recipient;   
  • identify several revocation options that, if used by the consumer, would be sufficient to revoke prior consent. Conversely, failure to use those options would not be effective to revoke consent; and 
  • Grant the CUNA petition and eliminate antiquated distinctions between landline and cell phone informational calls. 

The D.C. Court of Appeals recently vacated 2015 guidance that was overly broad and created legal compliance uncertainties for businesses. CUNA is engaged with the FCC and Congress to find a solution for credit union communication and was one of nearly 20 entities that filed a Petition for Declaratory Ruling to revise the definition of an ATDS.   


About CUNA     
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 110 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit