ANOTHER WORLD-CLASS R.E.A.C.H. COMMENT TO FCC HELPS TO PROTECT CONSUMERS AND LEAD GENERATORS ALIKE!

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Well as my inbox floods with requests for the 2026 Troutman Amin, LLP TCPA Annual Review, presented by Contact Center Compliance I wanted to take a moment to applaud Responsible Enterprises Against Consumer Harassment (R.E.A.C.H.) for their latest INCREDIBLE piece of advocacy.

On Monday R.E.A.C.H. filed its comments to the FCC’s recent omnibus Notice of Proposed Rulemaking on various TCPA/telecom and robocall mitigation issues.

You can read the entire comment (and you should) right here: REACH Comments on FNPRM

But for the busy here is the synopsis of the positions taken by R.E.A.C.H.

R.E.A.C.H. suggests the Commission:

  1. Retain its current abandonment limits to prevent abusive calls to consumers;
  2. Modify proposed revocation rules to reject upcoming “nuclear” opt-out requirements that work against businesses and consumers alike;
  3. Clarify a business may specify reasonable revocation methods a consumer can use, and if such a revocation method is established, the consumer must use such means to effectively revoke consent;
  4. Clarify that legacy prerecorded voice calls must continue to provide meaningful caller identification, and that any modernization of caller identification requirements should preserve consumers’ ability to readily understand who is calling, while maintaining appropriate safeguards against abuse;
  5. Ensure that any expansion of verified caller identity frameworks is accompanied by scalable minimum verification standards and robust privacy protections, so that identity signals do not mislead consumers and sensitive communications remain appropriately protected; and
  6. Encourage—but not mandate—the secure transmission of caller identity information, including through Rich Call Data, while prioritizing standardization, interoperability, cost containment, and competition.

Pretty sexy (and nerdy) stuff, but that’s just how R.E.A.C.H. rolls!

Need to give a MASSIVE shout out to John Barbret and Isaac Schloss here. Without those two this thing would NEVER have come together. Also need to acknowledge Steven Rosenfeld of my office who brought this all together like a wizard.

Finally I have to always thank Gayla Huber for her tremendous efforts not just to this comment but to the ongoing success of R.E.A.C.H. and its mission to clean up the lead generation industry for the benefit of all!

So DEEPLY impressed with all of you. Thank you. Thank you. Thank you!

And now to handing out reviews!

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. I’m not one to hold back. Compliments are merited. Your FCC filing in the FCC’s ECFS system was on-point and made a lot of sense, and coherently explains the position, persuasively, with being respect to protecting the ability to make calls while also contemplating consumer protections. Well done, really enjoyed reading that, and we look forward to supporting R.E.A.C.H.’s position with our own comments to the FCC.

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