WASHINGTON—NAFCU and CUNA have both said they support the establishment of a centralized, Federal Communications Commission (FCC)-supervised database to which all voice providers should be required to report reassigned numbers, the trade associations told the FCC in separate comment letters to the agency.
“CUNA believes that a national database under the auspices of the Commission and operated by a Commission-designated and supervised entity would best guarantee accurate and timely information on reassigned numbers,” the letter reads. “CUNA concurs with the Commission’s assessment that such an approach would allow the agency to oversee quality, appropriately limit access and preserve and protect the data.
This model has previously been used by the FCC and Federal Trade Commission in creating and maintaining the national “Do Not Call” registry.
Specifically, CUNA recommends:
- The database be affordable for smaller entities, such as credit unions, by using a fee structure for access that considers the needs of organizations conducting business on a regional, state or local level. The FCC should also provide free access to any reassigned numbers database to the same extent that free access is provided to the national “Do Not Call” registry
- All voice providers with access to numbers be required to report to the database to ensure comprehensive information
- Service providers should update the database in real time whenever a number is disconnected and classified as aging pursuant to the FCC’s numbering rules.
In addition, CUNA recommends the FCC creates a workable safe harbor from liability for callers that use the re-assigned database number, noting that this would be particularly appropriate for credit unions.
“Credit union communications with their member-owners are mostly informational in nature, often providing critically important financial information, and can include information related to the governance of the credit union,” the letter reads. “Credit unions do not target non-members or third parties with such communications. Credit unions should not have to fear potential liability if they have demonstrably used the reassigned number database yet mistakenly call a reassigned number.”
CUNA also urged the FCC to promptly revise its current re-assigned numbers rules.
NAFCU Regulatory Affairs Counsel Ann Kossachev said the FCC should establish a centralized database of reassigned numbers that is regularly updated by voice service providers in response to its inquiry on how the commission could address the problem of robocalls for those who have consented to receive calls but whose numbers have been reassigned.
"The onus of reporting reassigned numbers should lie with voice providers because they are the ultimate keepers of this valuable information," she wrote. She added that the FCC should have oversight over this database and that credit unions should have access to it at little to no cost.
"Credit unions are member-owned cooperative financial institutions that seek to serve the best interests of their members and make every attempt to contact their members with vital information regarding their accounts and services," Kossachev wrote. "As not-for-profits, credit unions have limited resources to provide their consistently high-quality products and services and any additional costs would put a huge strain on their ability to continue to do so."