Regulation takes effect on April 11th
Commencing on April 11, 2025, a new TCPA regulation will take effect that will allow consumers to more easily revoke their prior consent to receive robocalls or automated texts. The primary requirements under the new regulation are: (a) consumers can revoke their consent in any manner that is reasonable. Callers cannot require a prescribed method of revocation; (b) when a revocation or do-not-call request is received, it must be honored within ten days of receipt; (c) when a consumer revokes his or her consent, it is presumed that the revocation applies to both calls and text messages; (d) in cases where a consumer delivers the revocation via text message, senders are limited to a one-time confirmation message advising that no further text messages will be sent; and (e) consumers can choose to opt out of all calls and texts, even informational ones, and if the revocation is received in response to an informational message, as opposed to a marketing one, all robocalls and texts should stop, except for emergency ones.
The FCC also adopted a standardized list of specific words that, if received from a consumer in a text, must automatically be treated as a revocation of consent. These "magic words" are: “stop,” “quit,” “end,” “revoke,” “opt out,” "cancel," or "unsubscribe."
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Scott has focused on complex commercial litigation and arbitration involving advertising and marketing law, class action defense, administrative investigations, contractual disputes, consumer fraud, and business ...