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Business and Policy Areas
Business and Policy Areas

NACUBO Comments on Use of Autodialers

June 27, 2016

NACUBO recently offered comments to the Federal Communications Commission (FCC) on a notice of proposed rulemaking for the use of autodialers and mass texting systems.

The Telephone Consumer Protection Act (TCPA) prohibits calls to cellular telephones using autodialer technology without prior express consent from the dialed party.  Prerecorded messages and mass text messages are also prohibited without consent.

The Bipartisan Budget Act of 2015 included language that exempted entities from the prior express consent requirement if the calls were made for the purpose of collecting a debt owed to the United States government. The FCC is in the process of developing regulations to enforce that statutory requirement.

NACUBO's overarching comment to the FCC was that servicers "need to contact borrowers to provide timely and accurate information about their loans, well before a borrower is delinquent or has defaulted."  Using autodialers to reach borrowers to inform them of the various repayment methods for federal student loans benefits the students, institutions, and the federal government, NACUBO argued. 

In the submission, NACUBO endorsed portions of comments from the Student Loan Servicing Alliance, the American Association of Community Colleges, UNCF, the Coalition of Higher Education Assistance Organizations, the National Council of Higher Education Resources, and Nelnet, Inc.


Bryan Dickson
Senior Policy Analyst