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What Changed and What's Changing? Looking at the Telephone Consumer Protection Act and Military Lending Act
Tuesday, July 26, 2016 6:30 AM

Join Us for Compliance Webinar Wednesday, July 27

Do you have express permission to call your members’ cell phones for any purpose? Such calls can trigger costly penalties if you don’t understand the impact of the FCC’s 2015 interpretation of the Telephone Consumer Protection Act (TCPA), even if done for legitimate business purposes outside telemarketing. Are you lending to anyone in the military or to their dependents? If so, you may trigger actions under the revised Military Lending Act (MLA) regulations that become effective on Oct. 3, 2016.

Cornerstone’s Compliance Team will be offering a FREE conference call addressing the FCC’s 2015 interpretations of the TCPA and updates to the MLA.

Date: July 27, 2016
Time: 10 a.m. – 11:30 a.m. (CT)
More information and registration.

Learn what you need to know to ensure that your credit union is properly addressing major issues presented by these recent changes. Although this presentation is free, participation in the live event is limited, so sign up soon. The event will be archived for credit unions unable to attend the live event.

BACKGROUND

TCPA

The FCC’s 2015 clarifications to the TCPA have produced a great deal of confusion and concern over whether or not credit unions are properly managing phone-based interactions with members. The conference call will address:

  • Gaining proper express consent to make phone calls to members’ land lines and cell phones,
  • The FCC’s expansive definition of what an “autodialer” is, and determining if your current systems are included, triggering compliance burdens,
  • Managing contacts to cell phones,
  • Defining when and how a member can revoke consent to receive calls,
  • Handling reassigned or wrong number calls,
  • Understanding exceptions to TCPA rules, including emergency contacts, and
  • Other issues raised by the 2015 interpretations.

MLA

On July 21, 2015, the Department of Defense (DoD) issued a final rule updating its MLA regulations. These changes extend the scope of the MLA to include additional types of closed-end and open-end consumer products regularly offered by credit unions to closely match the definition of credit under Regulation Z. The conference call will address:

  • A brief history of the MLA,
  • What new kinds of credit will fall under MLA coverage as of Oct. 3,
  • Calculating the Military Annual Percentage Rate (MAPR),
  • Identifying covered borrowers,
  • Properly providing required disclosures,
  • Penalties and remedies for violations,
  • Cross-collateralization and deposit-secured accounts under the MLA,
  • How these changes impact credit unions whose field of membership does not include a large military component, and
  • Unresolved issues and how to deal with them.

Questions? Call 800-442-5762, ext. 8514, or 512-853-8514 or email Nathan Behncke at nbehncke@cornerstoneleague.coop.