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Occupancy and TCPA Gov’t Debt Among Comments Due in June
Friday, June 3, 2016 6:35 AM

Comments on the NCUA’s occupancy rule, student borrower loan communications and a government debt exemption from the Telephone Consumer Protection Act (TCPA) are all due this month.

Specific deadlines for June include:

  • June 6: TCPA proposal to create exemptions under the TCPA for calls made to a cell phone when collecting a debt owed to or guaranteed by the federal government. Notably for credit unions, the Federal Communications Commission is seeking comment on the meaning of “owed to or guaranteed by the United States.” This is relevant if it were interpreted broadly enough that it includes Small Business Administration loansor federally guaranteed mortgages;
     
  • June 12: Consumer Financial Protection Bureau request for information on communications to student loan borrowers regarding consumer decision-making when repaying student loans, including the presentation of information about alternative repayment options for federal loans; and
     
  • June 27: NCUA proposal that would eliminate a requirement in the current occupancy rule that a federal credit union must plan for, and eventually achieve, full occupancy of acquired premises. Instead, it allows for a credit union to achieve partial occupancy with an at least 50 percent use of premises by the credit union and partial occupancy can be maintained with not(assume this should be no?) plan for full occupancy. Comments are due to CUNA by June 20.