ABA/Joint Trades’ Letter to FCC in Support of Revisions to “Revoke All” Rule and “Provided Number” Condition

Dear Chairman Carr, Commissioner Gomez, and Commissioner Trusty:

The American Bankers Association (ABA), ACA International, American Financial Services Association, America's Credit Unions, Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, and Student Loan Servicing Alliance (collectively, the Associations) write to express our strong support for the draft Report and Order and Further Notice of Proposed Rulemaking (Draft Order) revising the Federal Communications Commission’s (Commission) "revoke all" rule. We also appreciate the revisions to the "provided number" condition to the exemption granted to ABA in 2015 for fraud alerts and certain other time-sensitive messages. The Associations strongly support the Draft Order and urge the Commission to vote to adopt it at its September 30 Open Meeting. We also ask the Commission to make the two modest, but important, edits requested by ABA in its ex parte letter submitted earlier today.

The Associations have long supported policies that protect consumers from illegally spoofed calls while ensuring consumers receive the time-sensitive and beneficial communications they expect from the financial institutions with which they do business. Regrettably, in a Report and Order issued in 2024 (2024 Order), the Commission stated that, once a consumer revokes consent under the Telephone Consumer Protection Act (TCPA) 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). Applying this provision, if a consumer replies "stop" to revoke consent to receive one type of message – for example, future autodialed past-due text messages – the caller must stop sending all future communications by phone or text on unrelated matters, such as warnings about unusual credit card transactions (fraud alerts), low-balance alerts, multi-factor authentication (MFA) messages, or utility calls.

Download the joint trades letter to read the full text.