Collector – October 2019 - 40

GOVERNMENTAFFAIRS

remittances rule, among others. Under the
Dodd-Frank Act, CFPB Director Kathy
Kraninger should be in place for four
more years, no matter who is in the White
House. Arguably, this means she should
be able to finalize the debt collection rule,
which was the first new rule she issued
under her tenure.
However, it would come as no
surprise in Washington, D.C., if a
different administration took steps to
force out a prior political appointee, or
otherwise inhibit her ability to complete
rulemakings. It would also come as
no surprise if the debt collection rule,
being Kraninger's first, could end up
on the chopping block with a new
president in office.
Notably, the effective date on rules
usually falls somewhere around a year
after they are finalized, and so much could
happen in Congress and at regulatory
agencies during that time. ACA is
preparing for all outcomes and is focused
on seeing the rule finalized in its best form
to promote clarity for the industry and
consumers alike.

ROBOCALLS AND THE TCPA
"Robocalls" and the Telephone Consumer
Protection Act garnered much attention
from Congress right out of the gate
in 2019. The U.S. House and Senate
passed their main bills on this topic,
by overwhelming margins, before the
summer recess.
As the Federal Communications
Commission continues to grapple with
SHAKEN/STIR, it is unclear how much
more congressional activity will be
happening surrounding this issue in 2020.
This year, the FCC identified combating
"robocalls" as a top priority. Most notably,
the June 2019 Declaratory Ruling stated that
voice service providers should provide callblocking programs to consumers by default
(on an opt-out basis) and block calls based
on "reasonable analytics." Voice service
providers were allowed to begin blocking
calls under the decision June 7, 2019.

40

"It will be interesting to see how lawmakers react
when they realize that many of their campaign
calls are being blocked under these new
technologies and FCC directives."

The comment process for SHAKEN/STIR
closed in late July, and ACA is awaiting
further action from the FCC. SHAKEN/
STIR could rear its head again in late 2019
or early 2020, requiring significant action
from the ARM industry.
As carriers continue to roll out their
call blocking programs, it's clear this
issue could continue to garner attention
from the media up until the presidential
election. It will also be interesting to
see how lawmakers react when they
realize that many of their campaign
calls are being blocked under these new
technologies and FCC directives.
Lastly, it's still not clear what action
the FCC will take on answering key
questions remanded to it from the D.C.
Circuit Court over a year and a half ago
in the aftermath of ACA's win challenging

the 2015 TCPA Order. As circuit courts
around the country remain split on
TCPA interpretations, ACA will continue
to work with its coalition to urge the
FCC to put aside politics and act on the
pressing question of what is considered
an autodialer.
These issues and the others of importance
to the accounts receivable management
industry, outlined in ACA's Advocacy
Agenda (found here: www.acainternational.
org/advocacy/advocacy-resources), will
require the association to have a constant
seat at the table and focus in Washington,
D.C., even as election fever encompasses the
rest of the country.
Leah Dempsey is vice president and senior
counsel of federal advocacy for ACA
International.

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Collector – October 2019

Table of Contents for the Digital Edition of Collector – October 2019

President’s Page
Industry News
Best Practices
FYI
Collection Tips
Accessibility From Every Angle
Information Transformation
Calendar
Honor Roll
Education Spotlight
Behind the Name
A.I. is Transforming Compliance. Are You Ready?
What to Watch in 2020
ACA’s Industry Advancement Program Provides Amicus Support in Key FDCPA Statute of Limitations Issue
ACA SearchPoint
Ad Index
Membership
Last Word
Collector – October 2019 - Cover1
Collector – October 2019 - Cover2
Collector – October 2019 - 1
Collector – October 2019 - 2
Collector – October 2019 - 3
Collector – October 2019 - 4
Collector – October 2019 - President’s Page
Collector – October 2019 - Industry News
Collector – October 2019 - 7
Collector – October 2019 - 8
Collector – October 2019 - 9
Collector – October 2019 - Best Practices
Collector – October 2019 - 11
Collector – October 2019 - FYI
Collector – October 2019 - 13
Collector – October 2019 - Collection Tips
Collector – October 2019 - 15
Collector – October 2019 - 16
Collector – October 2019 - 17
Collector – October 2019 - 18
Collector – October 2019 - 19
Collector – October 2019 - Accessibility From Every Angle
Collector – October 2019 - 21
Collector – October 2019 - 22
Collector – October 2019 - 23
Collector – October 2019 - Information Transformation
Collector – October 2019 - 25
Collector – October 2019 - 26
Collector – October 2019 - 27
Collector – October 2019 - 28
Collector – October 2019 - 29
Collector – October 2019 - Calendar
Collector – October 2019 - Honor Roll
Collector – October 2019 - Education Spotlight
Collector – October 2019 - 33
Collector – October 2019 - Behind the Name
Collector – October 2019 - 35
Collector – October 2019 - A.I. is Transforming Compliance. Are You Ready?
Collector – October 2019 - 37
Collector – October 2019 - What to Watch in 2020
Collector – October 2019 - 39
Collector – October 2019 - 40
Collector – October 2019 - 41
Collector – October 2019 - ACA’s Industry Advancement Program Provides Amicus Support in Key FDCPA Statute of Limitations Issue
Collector – October 2019 - 43
Collector – October 2019 - ACA SearchPoint
Collector – October 2019 - Ad Index
Collector – October 2019 - Membership
Collector – October 2019 - 47
Collector – October 2019 - Last Word
Collector – October 2019 - Cover3
Collector – October 2019 - Cover4
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