AFSA Responds to RFI on Approps from House Committee

Late last month, the House Committee on Appropriations requested information on suggested appropriations for upcoming fiscal 2020. Congressional committees often ask constituents and industry stakeholders for suggestions on how to most effectively distribute funds and set priorities.

On March 19, AFSA submitted its response, taking the opportunity to request that the committee take three specific actions.

The committee should preclude the Federal Communications Commission (FCC) from finalizing its proposed safeguards rule. The standards outlined in the proposed rule are not appropriate for all market participants. Moreover, the proposal is based on the rule passed two years ago by the New York Department of Financial Services. There is no data on the full impact of those regulations yet. Writing national rules without data on how the state regulation has worked is premature

Additionally, the committee should mandate that the FCC adopt a definition of “autodialer.” It should confirm that to be an automatic telephone dialing system (ATDS or autodialer), equipment must use a random or sequential number generator to store or produce numbers and dial those numbers without human intervention. Adopting this definition will ensure consumers can get important, timely information from businesses with which they patronize.

Finally, the committee should require that the Treasury to consult with the Department of Defense (DoD) regarding the department’s 2017 Military Lending Act (MLA) Interpretative Rule.