WASHINGTON–CUNA has signed on to a joint letter in support of the FCC’s goals of eliminating illegal automated calls while at the same time working to ensure consumers receive important, time-sensitive calls from financial institutions, healthcare providers and other legitimate entities.
CUNA noted it has long called on the FCC to ensure legitimate calls to consumers not fall under the agency’s efforts to eliminate illegal robocalls. Specifically, in the letter, CUNA and the other organizations call for modifications to the FCC’s June 25 Draft Order providing a safe harbor for voice service providers that block calls based on “reasonable analytics designed to identify unwanted calls,” as long as the analytics incorporates call authentication information into the blocking decision.
Letter to FinCEN
Separately, CUNA also sent a comment letter to the Financial Crimes Enforcement Network (FinCEN) in support of proposed updates to the PRA calculation for the collection of information for currency transaction report (CTR) requirements. This is a technical issue that does not impact credit unions, but rather only changes the Paperwork Reduction Act (PRA) analysis for new CTR rulemakings, CUNA noted.
“Adjustment to the PRA burden calculation will lead to greater accuracy in detailing the true cost to a financial institution for filing a CTR,” CUNA Senior Director of Advocacy and Counsel Senior Counsel for Payments and Cybersecurity Lance Noggle wrote. “We agree that the two additions to the PRA burden calculation are relevant in determining the entire cost for filing CTRs. The cost to obtain data required by the report that the filer does not need for its own bookkeeping, and maintaining, updating, and upgrading the technological infrastructure required to file and store the report are a necessary addition to the PRA calculation.”