In a comment letter to the Federal Communications Commission today, the American Bankers Association urged the FCC to continue developing a centrally administered database of phone numbers that have been relinquished by one individual and reassigned to another.
Prior to being struck down by a recent federal court ruling earlier this year, the FCC’s Telephone Consumer Protection Act regulations imposed liability for a call made in good faith to a party who has consented to receive the call but whose telephone number has been reassigned to another consumer, unbeknownst to the caller. Courts are expected to continue imposing liability for calls to reassigned numbers until the FCC issues new TCPA rules.
ABA also called on the FCC to provide a safe harbor for banks and other callers that use the database and to grant the joint petition submitted by ABA, the U.S. Chamber of Commerce and several other industry groups in early May asking for a new interpretation of the definition of an “automatic telephone dialing system,” commonly known as an “autodialer.”
