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As Shakespeare once quipped “[m]isery acquaints a man with strange bedfellows.”
We’re certainly enduring our share of misery right now, so perhaps we shouldn’t be surprised that strange alignments are presenting themselves here in TCPAWorld.
Consider–just yesterday the CFPB wrote a letter to the FCC encouraging it to allow banks and finance companies to make more automated calls to consumers. I mean… wow.
Not only that, but the consumer watchdog organization actually underscored the importance of such messages during the coronavirus pandemic and their effectiveness at spreading important information:
A limited number of automated calls from financial institutions to their customers alerting them to offers of forbearance; payment deferrals; fee waivers; extension or relaxation of repayment terms; loan modifications; and other programs, relief and resources relating to loans secured by homes or vehicles is an importance avenue to ensuring that consumers know the various options that may be available to them.
The letter–which can be found here— was sent in an effort to support the ABA’s recent petition to expand the very limited “emergency purposes” exemption that the FCC has recognized to date regarding COVID19-related calls. (Under the FCC’s current rule virtually no one can take advantage of the emergency exemption except for health workers and government officials.)
It's nice to see a primary regulator like the CFPB coming out in support of allowing banks and finance companies to provide timely information to consumers. Notably, however, the TCPA is just one roadblock to efficient assistance reaching folks in need—both the FCRA and the FDCPA also contain a thicket of ticky-tack requirements that might snare companies looking to provide assistance to consumers.
As we carefully watch CARES2 wander its way through the legislative process we’ll keep a careful eye out for consumer-driven rule-loosening of this sort. More to come.