CUNA reiterates need for longer period to implement consent revocation under TCPA

August 15, 2023

CUNA and ACA International filed reply comments with the Federal Communications Commission (FCC) regarding its proposal on revocation of consent under the Telephone Consumer Protection Act (TCPA). The proposal would require a 24-hour turnaround time to implement a consumer’s revocation of consent.

The organizations’ previous comments note the proposal would create “unreasonable, impracticable” standards.

“All commenters recognize that consumers have the right to revoke consent using reasonable methods. The calling community, however, recommends that the Commission codify reasonable limits on the methods of revocation that acknowledge the realities of revocation processes. There is a strong consensus, including consumer groups, that providing clarity and specificity on reasonable methods helps consumers by providing assurances that revocations will be honored.”

The reply comments also note initial comments are “virtually unanimous” in recommending a longer period of time to honor revocation requests than the proposed 24 hours.

CUNA and ACA International recommend 10 business days—as set forth in the CAN-SPAM Act—is a “reasonable middle ground” between commenters’ wide range of requests.

They also recommend FCC:

  • Allow for businesses to identify and confirm the scope of consent being revoked, so members fully understand the impact of the revocation on their services.
  • FCC establish specific safe harbor language to communicate a revocation of consent on texting platforms, such as “STOP.”