ABA Ex Parte Letter to FCC re: Meeting with Chairman Carr’s Office on “Revoke All” Rule

Dear Ms. Dortch,

On behalf of the American Bankers Association (ABA), I met virtually with Keelin Ferris, Legal Advisor to Chairman Brendan Carr, on September 21, 2026, and again by phone yesterday to discuss the draft Report and Order and Further Notice of Proposed Rulemaking (collectively, the Draft Order) released on September 9, 2026. Among other provisions, the Draft Order would address revocation of consent under the Telephone Consumer Protection Act (TCPA).

ABA thanks the Commission for scheduling a vote at its September 30 Open Meeting on adopting the Draft Order. Our members respect and carry out customer requests to revoke consent under the TCPA to receive autodialed or prerecorded voice calls or text messages. Regrettably, in a Report and Order issued in 2024 (2024 Order), the Commission stated that, once a consumer revokes consent to receive autodialed or prerecorded voice calls or text messages, the caller may no longer send the consumer any calls or text messages that require consent – even if that was not the consumer’s intent (the revoke all rule). The Commission also stated in that Order that a consumer may revoke consent through words that “a reasonable person would understand . . . to have conveyed a request to revoke consent.”

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