APRIL 11, 2025 IS COMING!: REMINDER ON NEW FCC REVOCATION RULES

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So did that massive enterprise SMS update with ANA yesterday. Tons of fun. Great content and questions and energy.

Received quite a few follow up emails. Many of them were on the new revocation rules that folks just don’t seem to be aware of.

First, watch this video because it breaks down everything in glorious detail:

But at a high level, come April 11, 2025 you will need to break up all messaging and voice calling across your enterprise into three tiers: i) marketing; ii) informational; iii) exempted.

Come April 11, 2025 a stop response will require ALL communications requiring the same or greater level of consent to cease based on these tiers.

So a “stop” to a marketing message will require all calls and texts requiring PEWC or PIEP to cease;

A “stop” to an informational/transaction call will require all calls and texts requiring any level of express consent to cease;

A “stop” to an exempt message—such as a fraud alert—will require all messages of any kind using regulated technology to cease.

This is a very large change from the current rules.

There is a small opportunity to “clarify” with the consumer what they intended with their opt out request, but it cannot be used as a rebuttal and if the consumer does not respond you have to apply the rubric above.

Not good.

Also unlike the FCC’s one-to-one rule THERE IS NO LEGAL CHALLENGE to this rule and there has been no effort by anybody to stay it (although R.E.A.C.H. is considering such an effort.)

Biggest change in telecom this year folks. Hope you’re all ready.

We will be discussing the fall out at LCOC III. Only about 30 hours left to get the best pricing! Hope to see you there.

Chat soon.

 

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Published by Eric "Czar" Troutman

The Czar of TCPAWorld Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems. Eric has built a national litigation practice based upon deep experience, rigorous analysis and extraordinary responsiveness. Eric and his team feel equally at home litigating multibillion dollar telecommunications class actions in federal court as they do developing and executing national litigation strategies for institutions facing an onslaught of individual TCPA matters. They thrive in each of these roles – delivering consistently excellent results – while never losing sight of the client experience. While many firms now tout TCPA expertise, Eric has been there from the beginning. He built one of the country’s first TCPA-only defense teams and began serving as national TCPA counsel for his clients nearly a decade ago. This perspective allows him to swiftly develop the right litigation strategies for dealing with recurring problems, without wasting time on tactics that are bound to fail. Eric’s rich historical perspective and encyclopedic knowledge of the TCPA landscape also make him an invaluable resource to institutional compliance teams struggling to comply with the shifting regulatory landscape. No task is too small – or too big. Indeed, Eric and his team have helped build TCPA-compliant systems and processes for some of the largest and most complex corporate entities in the country. He commonly works with in-house compliance counsel to build and implement enterprise and business-line specific TCPA solutions, performs TCPA audits and drafts and reviews proposed TCPA policies and procedures. He and his team also have the technical expertise necessary to assist call centers seeking to develop TCPA-resistant call path architecture or to modify existing telephony and software integration to better insulate from potential TCPA exposure. Eric has built a reputation for thought leadership. An avid blogger and speaker, he has been at the forefront of the industry’s effort to push for clarity and a return to sanity for the TCPA for years. He was selected to advocate for the financial services industry on important TCPA issues before the Federal Communications Commission and co-authored the nation’s only comprehensive practice guide on TCPA defense. In his spare time, Eric leads defense teams representing banks and other financial services companies in consumer finance litigation matters. He has experience representing clients in UCC, TILA, RESPA FCRA, CCRA, CLRA, FDCPA, RFDCPA and FCCPA claims, as well as in fraud and bank operations issues.

1 Comment

  1. Not a problem to stop across all tiers using Safe Select…….native feature

    Reply

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