This post was written by Christine E. Nielsen.
The FCC is seeking comments on industry group petitions for clarification and forbearance on the recently amended Telephone Consumer Protection Act (TCPA) Rules. A petition filed with the FCC by a Coalition of Mobile Engagement Providers specifically seeks clarification that the revised forms of consent are only required for new customers such that customers who previously provided valid consent will continue to receive requested communications without having to re-opt-in. The Direct Marketing Association (DMA) also petitioned the FCC to forbear enforcement of the disclosure requirements because, while those requirements were meant to be consistent with the disclosures required by the Federal Trade Commission (FTC), the DMA argues that they actually go beyond the FTC’s disclosure requirements. Comments are due to the FCC on December 2. You can read more about the new rules, the recent petitions, and the request for comments on the Global Regulatory Enforcement Law Blog’s related post.