Joint Trades' Ex Parte Letter to FCC re: Meeting with Consumer and Governmental Affairs Bureau Staff

Dear Ms. Dortch:

On Friday September 22, 2023, Jonathan Thessin, Vice President/Senior Counsel, Regulatory Compliance and Policy, American Bankers Association; Scott Purcell, Chief Executive Officer, ACA International; Elizabeth Sullivan, Senior Director of Advocacy and Counsel, Credit Union National Association; Amanda Smith, Senior Regulatory Affairs Counsel, National Association of Federally‐Insured Credit Unions; Leah Dempsey, Counsel for ACA International, Brownstein, Hyatt Farber Schreck; and the undersigned, counsel for the Credit Union National Association, met with staff of the Consumer and Governmental Affairs Committee identified on attachment A. During the meeting, the participants discussed the Federal Communications Commission's ongoing proceedings regarding revocation of consent under the Telephone Consumer Protection Act (TCPA) and certain of the Commission's proposals regarding call blocking, labeling and notification of blocking consistent with the comments filed by the aforementioned associations.

We reiterated our strong support for actions to remove bad actors and illegal traffic from the network. We noted that banks, credit unions, and other financial services providers – and their customers – are negatively impacted by bad actors that increasingly place calls that impersonate legitimate companies with intent to defraud. At the same time, it is key that the legitimate, often critical, calls that our members place are completed. We emphasized that certain calls for which consumers have provided consent—including fraud alerts, servicing calls, and past‐due notifications—are too often blocked by carriers and their analytic engine partners. Despite callers' compliance with TCPA regulations and adherence to best practices, such as scrubbing numbers against the Commission's reassigned numbers database to ensure that the number is still associated with the called party, carriers block or mislabel calls as spam or scam, virtually ensuring the call is not answered.

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