BPI and Joint Trades Comment on FCC’s Second Notice of Proposed Rulemaking on Illegal Text Messages

Introduction and Summary

The American Bankers Association, ACA International, American Financial
Services Association, America’s Credit Unions, Bank Policy Institute, Mortgage Bankers
Association, and Student Loan Servicing Alliance (the Associations)[1] appreciate the opportunity
to comment on the Second Further Notice of Proposed Rulemaking (Second Further Notice) in
the above-captioned proceeding.[2]

Texts that impersonate legitimate businesses cause tremendous harm to consumers and
undermine those businesses’ ability to communicate with their customers. The Associations have been strong proponents of regulatory proposals intended to curb these abusive and dangerous practices. In comments submitted during this rulemaking process, our primary objective has been to ensure that actions to curb illegal automated calls and texts also seek to minimize the blocking of lawful, consented-to communications and to provide effective redress mechanisms when erroneous blocking occurs.

To read the full comment letter, please click here, or click on the download button below.

[1] A description of each Association is in the Appendix.

[2] Targeting and Eliminating Unlawful Text Messages, Rules and Regulations Implementing the Tel. Consumer Prot. Act of 1991, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket Nos. 21-402, 02-278 & 17-59, Second Report and Order, Second Further Notice of Proposed Rulemaking in CG Docket Nos. 02-278 and 21-402, and Waiver Order in CG Docket No. 17-59, FCC 23-107 (Dec. 18, 2023) (Second Order or Second Further Notice).