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TCPA update, fraud prevention guide in July Compliance Monitor
The July Compliance Monitor, now available for download, includes articles detailing recent developments in the fight for clarity under the Telephone Consumer Protection Act (TCPA) and a compilation of NCUA guidance on internal controls to combat fraud.
NAFCU has consistently sought clarification related to the TCPA as credit unions have ceased important communications with members about their accounts over fear of inadvertently violating the rule. In the Monitor, NAFCU Regulatory Compliance Counsel André Cotten provides background on the law and the Federal Communications Commission's (FCC) 2015 declaratory ruling, which recently had key components vacated by the D.C. Circuit Court of Appeals.
Cotten's article includes further discussion on the definition of an autodialer, reassigned numbers and revocation of consent. He also details recent efforts by the FCC and others to address issues raised by recent court decisions, as well as resources available for credit unions while guidance is pending.
In another article, Reginald Watson, NAFCU's regulatory compliance counsel, offers a guide to NCUA guidance documents related to preventing fraud through internal controls, which Watson notes aren't always easy to locate. Watson explains board of directors' expectations for internal controls under the Federal Credit Union Act, and also summarizes the NCUA's supervisory committee and examiner's guides so credit unions better understand the regulator's expectations for fraud prevention.
A rundown of NAFCU resources to help credit unions comply with the Federal Reserve's changes to Regulation CC, which went into effect July 1, is included in this month's Monitor.
The July Monitor also features the Compliance Forum, which includes questions and answers relating to remote deposit capture, email advertisements and flood insurance and escrow premium requirements.
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