The American Bankers Association and the Consumer Bankers Association support the revised exemption proposal of the Cargo Airline Association, which would permit its members to send non-telemarketing package delivery notifications to mobile devices on a free-to-end-user basis without first obtaining the prior express consent of the recipients. Package delivery notifications are one of many categories of consumerfriendly informational communications that now are inhibited by the threat of massive class-action lawsuits based upon purported violations of the automated dialing provisions of the Telephone Consumer Protection Act. The grounds for exemption from those provisions suggested by the Cargo Airline Association - that package delivery messages not charged to the called party are consistent with the privacy interests the Telephone Consumer Protection Act is intended to protect - apply equally to free-to-end-user money transfer notifications, fraud alerts and other informational messages that financial institutions send to their customers and others. Accordingly, the American Bankers Association and Consumer Bankers Association are pleased that the Commission has asked for public comment on the Cargo Airline Association proposal, and urge that it be granted as promptly as possible.
To read the full Comment Letter, download the PDF.
EXECUTIVE SUMMARY
The American Bankers Association and the Consumer Bankers Association support the revised exemption proposal of the Cargo Airline Association, which would permit its members to send non-telemarketing package delivery notifications to mobile devices on a free-to-end-user basis without first obtaining the prior express consent of the recipients. Package delivery notifications are one of many categories of consumerfriendly informational communications that now are inhibited by the threat of massive class-action lawsuits based upon purported violations of the automated dialing provisions of the Telephone Consumer Protection Act. The grounds for exemption from those provisions suggested by the Cargo Airline Association - that package delivery messages not charged to the called party are consistent with the privacy interests the Telephone Consumer Protection Act is intended to protect - apply equally to free-to-end-user money transfer notifications, fraud alerts and other informational messages that financial institutions send to their customers and others. Accordingly, the American Bankers Association and Consumer Bankers Association are pleased that the Commission has asked for public comment on the Cargo Airline Association proposal, and urge that it be granted as promptly as possible.
To read the full Comment Letter, download the PDF.