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NAFCU sent member credit unions two Regulatory Alerts Tuesday breaking down the NCUA’s recently proposed rule related to charitable donation accounts (CDAs) and the Federal Communications Commission’s (FCC) proposed rules regarding consumers’ right to revoke consent to receive robocalls and robotexts.

In the Regulatory Alert on CDAs, NAFCU noted these accounts allow credit unions to hold otherwise-impermissible investments and use the proceeds of those investments to fund contributions to qualified charities. The NCUA’s current definition of a “qualified charity” is limited to 501(c)(3) organizations and the agency has proposed expanding the definition to 501(c)(19) organizations, which covers veterans’ organizations. NAFCU, along with the Defense Credit Union Council, had urged the agency to make this change.

NAFCU is seeking member credit union insights into whether:

• the expanded definition would encourage credit unions to make contributions to veterans’ organizations; and
• additional groups, organizations, or entities should be added to the “qualified charity” definition and what those should be.

Credit unions can submit feedback on the CDA proposal to NAFCU through the Regulatory Alert until July 14; comments are due to the NCUA July 31.

The Regulatory Alert on the FCC’s proposed rules on consent revocation noted that the proposal would:

• codify guidance published in 2015, which provides that consumers can revoke consent to receive robocalls and robotexts under the Telephone Consumer Protection Act (TCPA) through any reasonable means;
• require robocallers and robotexters to honor do-not-call requests within 24 hours of receipt;
• codify the FCC’s prior guidance that consumers only need to revoke consent once to stop all robocalls and robotexts from a covered entity; and
• limit wireless carriers’ authority to place certain non-charged autodialed calls, prerecorded calls, artificial voice calls, and robotexts to their customers.

Of note, NAFCU and other trades recently wrote to the FCC requesting the commission implement a reasonably fast remediation timeline when call carriers accidentally block legitimate texts, such as necessary fraud alerts from their financial institution. Additionally, the trades asked the FCC to broaden how the list of entities the consumer is giving consent to may be displayed or otherwise provided to the consumer.

Credit unions can submit feedback to NAFCU through the Regulatory Alert; comments are due to the FCC 30 days after it is published in the Federal Register.