We are just starting to move into the 21st century While we have had mobile banking for a long while, we are just now going to start offering push notifications for alerts on account activity (no advertising/offering other products). Are there any regulatory disclosures that are required?

Are the push notification coming through your mobile banking app or are you going to be pushing texts?

Well I thought only through the app but OP SVP just informed me it is through text messages

After yesterday - at least in the 11th Circuit, everyone is going to want to pay special attention to the TCPA requirements when it comes to text messsages.

In an en banc decision, the entire Court of Appeals for the Eleventh Circuit ruled yesterday that receiving a single unwanted text message is sufficient for an individual to have standing to sue the sender of the message in federal court for violating the Telephone Consumer Protection Act, and remanded the case back to a panel of Eleventh Circuit judges to consider the rest of the appeal.

https://www.accountsrecovery.net/20...ne-text-message-sufficient-for-standing/

Does this exemption from the December 2020 rule still apply? https://docs.fcc.gov/public/attachments/FCC-20-186A1.pdf

The Commission has exempted calls made by financial institutions to wireless consumers
subject to several conditions.105 The Commission noted that calls by financial institutions regarding
fraudulent transactions, security data breaches, and identity theft are “intended to address exigent
circumstances in which a quick, timely communication with a consumer could prevent considerable
consumer harms.”106 This exemption has been in place for five years, and we agree with commenters that
it remains in the public interest.107 Consistent with comments filed on this issue, we conclude that these
conditions satisfy section 8 of the TRACED Act. The exemption’s conditions include limitations on the
class of calling parties (financial institutions), the class of called parties (customers of the financial
institution), and the number of calls (no more than three calls per event over a three-day period for each
affected account).108 As a result, we conclude that no further action is required to bring this exemption
into compliance with section 8 of the TRACED Act. No commenter disagrees with this conclusion.109