ACA International, American Bankers Association, America’s Credit Unions, American Financial Services Association, Defense Credit Union Council, Bank Policy Institute, Mortgage Bankers Association, Student Loan Servicing Alliance, and Consumer Bankers Association (collectively, the Associations) commend the Federal Communications Commission for issuing the draft Ninth Further Notice of Proposed Rulemaking (Draft Notice).[1] Efficient, effective communications are essential if banks, credit unions, other financial services providers, electric utility companies, and other businesses are to serve their customers and comply with their regulatory obligations. The Associations have long called for the Commission to revise its Telephone Consumer Protection Act (TCPA) rules to ensure our members can send time-critical, non-telemarketing messages to customers promptly.[2] We applaud the Commission for issuing a Draft Notice that proposes landmark, commonsense reforms to the Commission’s outdated TCPA rules while advancing proposals to further protect consumers from fraudulent calls.
The Associations have in particular supported the initiation of a rulemaking to reverse the Commission’s revoke-all rule. As set forth the below, we respectfully request that the
Commission also adopt an order extending the current April 11, 2026 deadline for implementing the revoke-all rule. We also appreciate that the Commission proposes to permit callers to designate the exclusive means by which consumers may revoke consent to receive autodialed or prerecorded or artificial voice calls.[3] This will benefit consumers and businesses alike by discouraging consumers from sending messages with non-standard text and by better ensuring businesses can process revocations quickly and efficiently.
We also commend the Commission for proposing enhancements to the STIR/SHAKEN call authentication framework, which will promote consumers’ confidence that the calls they receive are legitimate. Fraudulent calls that impersonate businesses pose a serious risk to consumers and erode trust in communications from the business. We are reviewing these draft provisions closely and look forward to providing comment on them once the Commission adopts the Draft Notice.
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[1] Advanced Methods to Target and Eliminate Unlawful Robocalls, et al, CG Docket Nos. 17-59, 02-278, 25-307, and WC Docket No. 17-97, FCC-CIRC2510-07 (rel. Oct. 7, 2025) [hereinafter, Draft Notice].
[2] See, e.g., Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991 & Delete, Delete, Delete, CG Docket Nos. 02-278 & 25-133, Comments of Am. Bankers Ass’n et al. (filed Apr. 11, 2025), https://www.fcc.gov/ecfs/document/104122423211014/1; id., Comments of ACA Int’l (filed Apr. 11, 2025), https://www.fcc.gov/ecfs/document/1041181591094/1.
[3] Id., ¶ 105-06.
