In February 2024, the FCC adopted a Report and Order imposing a number of new TCPA caller and texter compliance obligations in connection with consumer revocation requests, which are applicable to calls and text messages that otherwise require consent under the TCPA and the FCC’s rules. In an October 11, 2024 Public Notice, the FCC announced that it has received Office of Management and Budget approval of the opt-out rules, and that the rules will become effective on April 11, 2025.
Among other things, under the new rules, text message senders must honor revocation requests in a timely manner made through seven specific keywords (stop, quit, end, revoke, opt out, cancel, and unsubscribe). Text message senders must also treat, based on “totality of the circumstances” analysis, other “reasonable” natural language text-backs by consumers as consent revocations. The order also provided that callers and senders may not mandate an exclusive means of consent revocation that precludes the use of other methods. You can read more about the adopted rules in our previous blog post here.
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