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NAFCU, in a letter Thursday, urged the Federal Communications Commission (FCC) to create a single, FCC-designated database to aid in the elimination of illegal robocalls. NAFCU has voiced its support for the creation of a reassigned numbers database overseen by the FCC since last year.

NAFCU Senior Regulatory Affairs Counsel Ann Kossachev sent the letter in response to the FCC's second further notice of proposed rulemaking related to calls made to reassigned numbers and liability under the Telephone Consumer Protection Act (TCPA).

Kossachev noted that there are some existing tools to help callers identify which numbers have been reassigned to a new consumer after being disconnected, but even the FCC has acknowledged that those are "incomplete and not timely updated."

"NAFCU is hopeful that the creation of a centralized reassigned numbers database will provide some relief from TCPA liability to credit unions acting in good faith in contacting their members," Kossachev wrote.

The letter further details components NAFCU would like to see included in a formal rulemaking to create a centralized reassigned numbers database, including the type of information needed, standards to update information in a timely manner, and mandatory reporting requirements, among others. Kossachev explicitly requests that the FCC create a safe harbor for callers who inadvertently make calls to reassigned numbers after checking the database, and also exempt credit unions from any cost associated with using the reassigned numbers database.

NAFCU has actively worked with the FCC over the past three years to obtain more clarity and flexibility under the TCPA so credit unions can contact their members without fear of breaking the law. NAFCU President and CEO Dan Berger met with FCC Chairman Ajit Pai in May to discuss credit unions' concerns and next steps following the U.S. Court of Appeals for the D.C. Circuit's decision that invalidated the FCC's definition of "autodialer" and rejected its interpretation of when a caller violates the TCPA by calling a reassigned number.