As reported by Legal News Platform JD Supra, significant changes have emerged in the approach towards Telephone Consumer Protection Act (TCPA) interagency examination procedures. The twofold developments were driven by the Office of the Comptroller of the Currency (OCC).
The first change, implemented on November 2, involved the publication of revisions to the TCPA’s interagency examination procedures, which are currently employed by the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the OCC itself.
The second adaptation involved the OCC explicitly declaring its decision to rescind an earlier TCPA section, specifically the “Telephone Consumer Protection Act and Junk Fax Protection Act” segment of the “Other Consumer Protection Laws and Regulations” booklet of the Comptroller’s Handbook.
The OCC further elucidated upon the purpose of these modifications, stating this adjustment was enacted to enable OCC examiners to place reliance upon newly instituted interagency procedures.
The details of the interagency procedures revision and its broader implications for consumer protection laws remain to be seen. The legal field eagerly awaits clarity on the operational details of these revisions and how it might alter their application of TCPA laws and regulations. Legal experts from Orrick, Herrington & Sutcliffe LLP elaborated on these developments, among other aspects.
As these novel changes begin to effectuate, legal professionals should anticipate alterations in consumer protection landscapes and adjust their current practices accordingly.