The Telephone Consumer Protection Act: A Review of ACA Int'l v. FCC

Written by André B. Cotten, Regulatory Compliance Counsel, NAFCU

Credit unions have struggled to comply with Telephone Consumer Protection Act (TCPA or the Act) since the 2015 Declaratory Ruling was released by the Federal Communications Commission (FCC). NAFCU has published two prior newsletter articles about the scope of the TCPA and ongoing operational challenges.  After an overview of the TCPA's history, we will discuss the most recent litigation in the District of Columbia Circuit Court of Appeals and then take a look forward since the court vacated key components of the 2015 Declaratory Ruling.