WASHINGTON-CUNA recently appealed to the Office of Management and Budget to deny approval of the Federal Communications Commission's revised rule on unsolicited advertising faxes. In its official comment letter, CUNA Assistant General Counsel Jeff Bloch wrote that the FCC's Do-Not-Fax rule under the Telephone Consumer Protection Act violates the Paperwork Reduction Act. The credit union trade association argued that the FCC "grossly underestimated" the businesses that would fall under the new regulation and the man-hours and cost involved in keeping the records. According to CUNA's letter, the FCC estimated one hour per year per business for compliance for 20,000 businesses to fall under the regulation. The regulation would require businesses to obtain written, signed approvals to receive advertising faxes from its members and others, including the fax number. FCC also eliminated the previous "established business relationship" standard, "meaning that a business may not send faxes with any advertising content to their own customers – even in response to a customer's request – without first obtaining written, signed permission," Bloch wrote. CUNA relies heavily on fax communications with its member credit unions, he explained, which the members have already expressed interest in. In addition, the rule also applies to those member credit unions sending out fax advertisements. "These requirements represent a staggering new paperwork burden on nearly all U.S. businesses, including trade associations, such as CUNA, as well as those credit unions that also communicate by fax," Bloch said in the letter.