CUNA Submits Comments to FCC Regarding Reassigned Numbers Database
CUNA filed a comment letter to the FCC regarding its proposal to create a Reassigned Numbers Database for purposes of compliance with the Telephone Consumer Protection Act (TCPA). Our comments state that the Commission should establish a comprehensive, easy-to-use and affordable reassigned numbers database and provide a safe harbor from TCPA liability for calling a reassigned number where the caller utilized the database, along the lines of the Do Not Call registry provisions.
“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.”
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.
USAA Files Suit Against Wells Fargo For RDC Patent Infringement
USAA filed suit against Well Fargo last week in U.S. District Court for the Eastern District of Texas for intellectual property infringement stemming from Well’s remote deposit capture (RDC) products. USAA has been seeking licensing fees from credit unions and banks that use remote deposit capture technology. The complaint was filed Thursday in U.S. District Court for the Eastern District of Texas.
This appears to be the first lawsuit that USAA has filed against a financial institution to enforce their patents although USAA had previously litigated RDC patents with technology vendor Mitek. CUNA has been following this issue closely and had recently surveyed credit unions asking for details on their RDC offerings to further analyze the issue. An information webinar with CUNA staff and outside counsel is available here.
Source: CUNA Removing Barriers Blog
U. S. Faster Payments Council Survey
Last week CUNA hosted a webinar that provided comprehensive information on the Federal Reserve Board's proposed U.S. Faster Payments Council. If you were unable to join, you can listen to a recording here.
As discussed on the webinar, please use the following survey to provide your feedback on the proposed U.S. Faster Payments Council governance framework via a brief, 8-question survey.
The U.S. Faster Payments Council represents the work of the Governance Framework Formation Team, a diverse group of payments industry stakeholders that was established by the former Faster Payments Task Force to advance the first recommendation of its final report. The GFFT's goal is to develop a faster payments governance framework, inclusive of all stakeholders, to make decisions to facilitate interoperability and achieve ubiquity of faster payments in 2020, as well as navigate future challenges as technology and end-user needs evolve.
Establishing an industry governance framework is critical to sustaining progress and successfully executing many of the task force's recommendations, and the Governance Framework Formation team appreciates your feedback and participation in this important next step in the payment system improvement initiative.
Click here to read the Operating Vision of the U.S. Faster Payments Council and provide more comprehensive feedback.
Source: CUNA Advocacy
Keeping up with CUNA Advocacy
To stay abreast of the issues on which CUNA has provided input to lawmakers and regulators, here is a list of those topics.
CUNA Advocacy Update
The CUNA Advocacy Update is published at the beginning of every week and keeps you on top of the most important changes in Washington for credit unions--and what CUNA is doing to monitor, analyze, and influence government agencies and federal law. To receive this update, click on “Get CUNA Updates” on the CUNA Advocacy page. Additional Advocacy efforts may also be found under CUNA’s Removing Barriers blog. With the recent updates to CUNA’s website, Advocacy information has also changed. To view recent advocacy issues and see ways your credit union can become involved, visit the Priorities or Actions pages.
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