2017 Survey on Impact of TCPA Rules

 

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* 1. How difficult has it been for your credit union to determine whether it is compliant with the TCPA (Telephone Consumer Protection Act)?

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* 2. Which, if any, of the following methods does your credit union use to communicate with members for account-, product- or other related reasons? (Check all that apply.)

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* 3. For which, if any, of the following situations does your credit union communicate with members, using one or more of the above methods? (Check all that apply.)

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* 4. If your credit union uses some form of artificial/pre-recorded voice messages over the phone, please answer Q. #4 thru Q. #6. Otherwise, please skip to Q. #7.

First, can your phone-calling system distinguish between a land line and a cell phone when calling a member?

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* 5. If your phone-calling system is not currently used as an autodialer, does it have the future capability of being used as an autodialer? (Note the FCC's July 2015 Order finds that the capacity of an autodialer is not limited to its current configuration but also includes its potential functionalities. And, a footnote says this includes equipment that can be activated or de-activated, and features that can be added to the equipment's overall functionality through software changes or updates.)

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* 6. Does your credit union have a way to make an automated phone call free/no charge to the end-user?

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* 7. Please indicate how strongly you agree or disagree with each of the following statements.

  Strongly agree Somewhat agree Somewhat disagree Strongly disagree No opinion
We have cut back on, or discontinued, texting members as a direct result of TCPA
Our credit union is able to distinguish whether its various calling devices are an autodialer or not
TCPA has caused our credit union to cut back or discontinue calling members over the phone using artificial/pre-recorded voice messages as a direct result of TCPA
Our members are usually pleased to receive the account updates we provide via text or artificial/pre-recorded voice messages to their cellphones

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* 8. How much in additional costs - if any - has your credit union incurred as a result of the TCPA? (This could include, for example: increasing call center staff, purchasing or making enhancements to your phone-calling systems, contracting with vendors, seeking outside legal opinions on TCPA compliance, inability to collect on outstanding debt, or taking other steps as a direct result of the 2015 rule changes to TCPA). If your credit union has not incurred any such additional costs, please check "None ($0)."

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* 9. Please rank each of the four requirements (from the July 2015 TCPA Order) below from 1 to 4, based on how problematic/confusing each has been for your credit union, in its efforts to remain compliant with TCPA. Please give your most problematic requirement a “1,” and so on, giving the least problematic/confusing item a “4.” Please use each of the numbers, 1 through 4, only once.

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* 10. How concerned, if at all, are you with each of the following? (Please check one box in each row.)

  Very concerned Somewhat concerned Not very concerned Not at all concerned
Your credit union’s TCPA liability for collection agencies or other 3rd-party vendors your credit union uses
Member communication having to be unnecessarily curtailed
Future class action law suits/litigation resulting from TCPA rules

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* 11. Has your credit union received any demand letters threatening TCPA lawsuits?

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* 12. How problematic would a TCPA lawsuit be for your credit union/membership? (Statutory damages are $500 per call for a technical violation or up to $1,500 per call if willful.)

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* 13. Which, if any, of the following types of messages/communications to your members have been hindered, lessened, or impeded as a direct result of the TCPA? (Check all that apply.)

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* 14. What is your credit union's asset size?

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* 15. What state is your credit union's main office located in?

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* 16. (OPTIONAL)  If you would be willing to share additional thoughts, insights and perspectives with CUNA Advocacy staff regarding TCPA, please provide us your contact information, below.

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