Last week, the FTC filed comments regarding the FCC's recent June 6 Notice of Proposed Rulemaking. 

Recall that as part of the Congressional Bipartisan Budget Act, Congress exempted certain collections calls from the TCPA.  Congress also directed the FCC to make behavioral rules for such newly exempted calls.  These calls would include, for example, calls to collect on tax debts and government-backed student loans and mortgages. 

On May 6, the FCC proposed a number of rules about the frequency and duration of such calls, and other restrictions.  In its comments, the FTC expressed concern because they field numerous complaints about collections robocalls.  Among other restrictions, the FTC recommended that the new TCPA exemption only apply once a consumer is in "Default." 

The FTC also recommended that the exemption only cover calls to the individual debtor, rather than others.  The FTC also urged the FCC to create rules about the security of any data collected during the exempted calls.  On the same date, the CFPB also filed comments about the NPRM.