PJ Hoffman, regulatory affairs counsel for the National Association of Federal Credit Unions, told the FTC on Wednesday that its telemarketing sales rule may have unintended consequences for credit unions.
In a letter to the FTC, Hoffman said that while the commission’s proposed changes to the TSR do not apply explicitly to federal credit unions, the changes would apply to state-chartered credit unions and third-party telemarketers hired by both federal and state-chartered credit unions.
“NAFCU generally supports the FTC’s efforts to combat fraud in novel payment methods,” Hoffman said. “NAFCU does have concerns about potential unintended consequences from this rule on payment systems such as remotely created checks, which are covered under the Federal Reserve Board’s 2011 Regulation CC proposal that has not yet been finalized. Many credit unions provide innovative products and services such as mobile check capture and other mobile banking services for their members. While this rule does not directly affect those products, it is essential that the FTC work closely with the Federal Reserve Board of Governors, the Consumer Financial Protection Bureau, and other stakeholders to ensure that there are no negative effects on payments systems.”