Summary of Text and Robocalls Final Rule
Updated 10/06/2025
On August 29, 2025, the Federal Communications Commission (“FCC”) issued a final rule to address the Eleventh Circuit United States Court of Appeals decision which revised section 47 CFR 64.1200(f)(9) and reinstated the prior version. This final rule supports the court’s ruling that the proposed revised paragraph regarding prior express consent seemed to be “unnecessary and potentially burdensome”. Key Takeaways:
• This rule applies to financial institutions, savings associations, and credit unions that engage in telemarketing activities as defined by the TCPA regardless of asset size.
• The definition of prior express consent as mentioned in section 47 CFR 64.1200(f)(9) was revised thus eliminating the requirement for comparison shopping websites to obtain consumer consent one seller at a time.
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