Compliance Question of the Week

We’re working with a credit bureau to offer a credit card solicitation to select members. The results of our pre-screen criteria indicated that a certain number of members had selected “do not solicit.” We’re thinking this pertains to those who have contacted the credit bureau(s) to remove their names from pre-screened offers. Is this correct? And are there any state laws we should know about concerning “do not solicit”?

Actually, the “do not solicit” information you are receiving pertains to the National Do Not Call Registry.

When a member chooses to opt out of prescreened offers under the Fair Credit Reporting Act (FCRA), the effect will be to have their name and address excluded from any list provided by a consumer reporting agency. In essence, they would not show up on the prescreened list you received from the credit bureau.

The National Do Not Call Registry pertains to receiving marketing offers made by phone calls to the designated phone number. But there is an exemption if you have an existing business relationship with that person.

Under Oregon’s No Call law, certain solicitation calls are allowed, including:

  • Calls from public agencies or charitable organizations to which you belong, or to which you have previously donated or expressed interest in making a donation;
  • Calls that are made in response to your request that a company call you;
  • Calls that ask for your opinion or vote; and
  • Calls from companies you have bought from in the past, or a “predecessor of a business enterprise” for certain financial institutions.

Washington State does not have any specific requirements over the National Do Not Call List

Related Links:

FCRA 604 (e)
Do Not Call Registry
Oregon DOJ Do Not Call

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Advocacy News, Compliance.