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NAFCU remains concerned that the Federal Communications Commission's interpretation of the Telephone Consumer Protection Act is harming consumers by reducing necessary communications regarding their financial services, NAFCU's Carrie Hunt told the commission Monday.

Hunt, NAFCU's executive vice president of government affairs and general counsel, wrote the FCC regarding its notice of proposed rulemaking to implement TCPA changes provided under the Bipartisan Budget Act of 2015.

She wrote that NAFCU and its members appreciate the FCC's consideration of the exemption under the TCPA to remove the current consent requirement for robocalls made for the sole purpose of collecting federal debt. However, she noted that NAFCU believes this exemption should be expanded "to facilitate communications with struggling or delinquent borrowers."

Hunt also said the FCC's one-call limitation on reassigned numbers doesn't provide enough flexibility to credit unions. Making one call might not generate any information indicating the number was reassigned, she wrote.

FCC's proposal would also restrict the number of debt collection calls to three per month, per delinquency – even if the calls go unanswered by the consumer. She said the FCC should remove the requirement that unanswered calls count toward the three-call limitation.

She also asked FCC to revisit its definition of an "autodialer," noting the definition "leaves unclear what type of technology is actually covered." She wrote that the commission's current definition, which is included in this proposal, will "discourage credit unions from making important communications to their members about their financial accounts for fear of violating the regulation and possibly incurring substantial liability."