WASHINGTON—CUNA has sent a set of proposals to the Federal Communications Commission to encourage the use of a reassigned number database (RND) and reduce the number of calls to reassigned numbers.
CUNA filed the comments with the FCC in response to an agency request for feedback on fees and other RND issues.
“CUNA has been a strong supporter of the RND since the FCC proposed its development in 2017. In its previous filings, CUNA has urged that the use of the RND be affordable and that the Commission look to elements of the fee structure for the Do Not Call (“DNC”) Registry as a model… It has also become clear that the development of the RND is far more complex, and potentially costly, than the Commission assumed when it authorized its creation in 2018,” the letter reads. “[FCC] is still unable to provide any estimates of the startup or operational costs of the RND, leaving parties to comment on a fee structure without any information regarding potential fee levels. The Commission should allow stakeholders to further comment once cost estimates are available.”
Specific Recommendations
Specifically, CUNA called on the FCC to take the following actions:
- The FCC should, given the delay in setting up its RND, revisit the definition of “called party” and find that it refers to the intended recipient of a call
- Provide free access to the data base for tax exempt non-profit institutions like credit unions and exempt limited usage (benefitting small businesses), which would be consistent with the way the do-not-call registry works
- Database users should not have to reimburse carriers for database startup costs to the extent carriers have passed those costs through to their own customers
- Adopt the recommendation to expand the safe harbor