ABA Ex Parte Letter re: Meeting with FCC CGB Staff on ‘Revoke All’ Rule

Dear Ms. Dortch,

On July 21, 2026, Jonathan Thessin of the American Bankers Association (ABA), Patrick Crotty of the National Consumer Law Center (NCLC), and Michael Pryor of Brownstein Hyatt Farber Schreck, LLP, on behalf of ACA International, met with Eduard Bartholme, Zac Champ, Wesley Platt, and Richard Smith of the Federal Communications Commission's (Commission) Consumer and Governmental Affairs Bureau.

ABA, NCLC, and ACA International share a common goal to ensure that consumers' revocations of consent to receive autodialed or prerecorded voice calls and text messages under the Telephone Consumer Protection Act (TCPA) are accurately and efficiently processed. During the meeting, we expressed our concern that aspects of the Report and Order (Order) released by the Commission on February 16, 2024 may undermine that goal and discussed the attached revisions that our organizations proposed on June 30, 2026. We explained that the proposed revisions were the product of numerous discussions among our three organizations and had been reviewed by a group of bank in-house TCPA counsel and separate attorneys who advise NCLC.

The proposed revisions allow the caller to interpret a revocation request as applying only to the category of messages to which the revocation was directed, while also requiring the caller to provide notice of how revocation will be construed and a means for the consumer to revoke consent with respect to all messages requiring consent. The revisions also allow a caller to designate a prescribed list of exclusive, reasonable means of revocation in the message sent to the called party.

We believe this language effectuates the objective of the Order’s provisions governing revocation of consent, while better ensuring that consumers are not inadvertently cut off from all communications from the companies with whom they do business based on sending a single "stop" message in response to one type of message from that company.

The current effective date of the provisions governing revocation of consent is January 31, 2027. During the meeting, the organizations asked the Commission, if it revises the Order, to extend the effective date of those revisions to 12 months after the revisions are finalized. This limited extension would promote the public interest by providing a reasonable period of time for banks and other callers to design and implement processes to comply with the revised rule.

Thank you for your consideration of these proposed revisions to the Order.

Sincerely,
American Bankers Association
National Consumer Law Center
ACA International