Earlier this week, the American Financial Services Association joined the American Bankers Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and Student Loan Servicing Alliance in a comment letter to the Federal Communications Commission (FCC). In its Notice of Proposed Rulemaking, the FCC proposes to codify and, in certain respects, expand its 2015 ruling that consumers who provide prior express consent under the Telephone Consumer Protection Act (TCPA) to receive autodialed or prerecorded voice calls or text messages may revoke consent through “any reasonable means.”
The provisions that the FCC proposes to codify are broad and ambiguous, making it difficult for businesses to ensure that they are correctly following the guidelines while avoiding harm to their customers. The letter from the joint trade groups offers several suggestions for improving the proposed rule. Some of the suggestions include:
- The FCC should establish and publicize a standardized set of words like “STOP,” “QUIT,” “END,” or “UNSUBSCRIBE” that, if used, would create a presumption that the revocation attempt is reasonable.
- The FCC should state in the regulatory text that, absent a clear expression by the consumer to the contrary, a single revocation applies only to the type of information in the original call or text message (e.g., past-due notices concerning a specific account).
- The FCC should adopt a six-business day requirement for callers to process revocation requests and requests to be added to the caller’s company specific do-not-call list.
- If the proposed changes are finalized, the FCC should provide at least 18 months for companies to implement the changes.
Joint Trades Comment on FCC TCPA Noticed of Proposed Rulemaking TCPA
Aug 03, 2023
Earlier this week, the American Financial Services Association joined the American Bankers Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education… Read the rest
Elevate in Salt Lake | Laura Udis
Aug 02, 2023
Join Laura Udis, Small Dollar, Marketplace, and Installment Lending Program Manager in the Consumer Financial Protection Bureau’s Research, Markets, and Regulations Division, for a dialogue highlighting some of the CFPB’s recent activity… Read the rest
AFSA Comments on Anti-Consumer Arbitration Provisions
Aug 02, 2023
Last week, the American Financial Services Association, joined by 200 other trade associations, submitted a comment letter to Members of Congress opposing anti-arbitration clauses and provisions that have been recently introduced.… Read the rest
Featured Business Partner | Amsive
Aug 01, 2023
The featured Business Partner for the month of August is Amsive.
Consumers signal individuality in all kinds of ways. Today marketers must listen and act on those signals. At Amsive, we give you the tools to know more and the services to do more.… Read the rest
Become a Business Partner Member today!
Aug 01, 2023
For just the month of August, AFSA is running a promotion you won’t want to miss!
Become a Business Partner by August 31st and receive a complimentary registration to the 2023 AFSA Annual Meeting in Salt Lake City, a $1,550 value!
As an AFSA Business… Read the rest
Economic Perceptions vs. Reality
Aug 01, 2023
A new CBS News/YouGov national poll deals mostly with politics, but since most politics influences policy, especially the economy, the results are worth considering.
In the survey, a significant majority of U.S. adults were reported to … Read the rest
About Those Rejection Rates
Jul 31, 2023
Several recent news stories have reported on historically high rejection rates for auto loans (see here, here, and here for example). But policymakers, as well as the media, should ensure they have the proper context for this data.
It is … Read the rest
WANTED: Dynamic Podcast Guests
Jul 28, 2023
Pitch the Extra Credit Podcast: On the Lookout for Dynamic Guests
Want to share innovative content, fresh ideas and reach consumer credit and vehicle finance industry leaders?
AFSA’s well-known Extra Credit Podcast is once again looking… Read the rest
CFPB Releases Supervisory Highlights Report
Jul 28, 2023
The Consumer Financial Protection Bureau (CFPB) this week released a new Supervisory Highlights report. In doing so, it announced, “CFPB Exams Find Unfair, Deceptive, and Abusive Practices Across a Wide Array of Consumer Financial Product… Read the rest
LISTEN | Changing Perspective on Auto Finance
Jul 27, 2023
In this edition of the AFSA Extra Credit Podcast, we chat with Robert Steenbergh, Founder & CEO of AutoPayPlus which offers consumers a flexible auto financing schedule that matches payments with paychecks.
We have a broad conversation… Read the rest