FCC 于 2026-09-09 公布 TCPA「撤销同意」规则草案（Report and Order + FNPRM），拟允许按类别撤销、指定唯一撤销渠道并放宽金融机构反欺诈提醒豁免，仅为 9 月 30 日会议待审议稿，非正式行动

September 9, 2026 FCC FACT SHEET* Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991 Report and Order and Further Notice of Proposed Rulemaking – CG Docket No. 02-278 Background: The Commission receives more complaints about illegal robocalls that defraud and annoy consumers than any other issue, and the Commission has taken a variety of measures to protect consumers from such calls. At the same time, many lawful robocalls provide important, time-sensitive information—such as a medical appointment reminder or a fraud alert—that consumers want to receive. The right to grant and revoke consent to receive such calls is fundamental to empowering consumers to decide which calls that they wish to receive. This Report and Order would modernize the TCPA rules to ensure that consumers have easily accessible ways to revoke consent while streamlining callers’ ability to process revocation requests. The Further Notice of Proposed Rulemaking would seek comment on additional revisions to ensure that the Commission’s TCPA rules continue to reflect advances in technology and industry practices. What the Report and Order Would Do: o Allow callers to interpret a revocation request as applying only to the specific category of informational robocalls to which the revocation was directed and not all robocalls for which consent was given; o Allow callers to designate an exclusive means to revoke consent; o Modify the exemption from the consent requirement for financial institutions to allow them to more easily alert customers to fraudulent activity on their account; and, o Delegate authority to the Consumer and Governmental Affairs Bureau to review the rules implementing the TCPA to ensure that those rules are clear and easy to understand. What the Further Notice of Proposed Rulemaking Would Do: o Seek comment on updating various TCPA-related rules including revisiting the timeframe for callers to honor revocation requests, requiring two-way texting functionality to allow for revocation via reply text, requiring callers to provide a method to revoke consent to all robocalls, and the treatment of affiliates. * This document is being released as part of a “permit-but-disclose” proceeding. Any presentations or views on the subject expressed to the Commission or its staff, including by email, must be filed in CG Docket No. 02-278, which may be accessed via the Electronic Comment Filing System (https://www.fcc.gov/ecfs). Before filing, participants should familiarize themselves with the Commission’s ex parte rules, including the general prohibition on presentations (written and oral) on matters listed on the Sunshine Agenda, which is typically released a week prior to the Commission’s meeting. See 47 CFR § 1.1200 et seq. Federal Communications Commission FCC-CIRC 2609-05 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) Rules and Regulations Implementing the ) CG Docket No. 02-278 Telephone Consumer Protection Act of 1991 ) REPORT AND ORDER AND FURTHER NOTICE OF PROPOSED RULEMAKING* Adopted: [ ] Released: [ ] Comment Date: [30 days after publication in the Federal Register] Reply Date: [60 days after publication in the Federal Register] By the Commission: I. INTRODUCTION 1. The Commission receives more complaints about illegal robocalls that defraud and annoy consumers than any other issue, and we have taken a variety of measures to protect consumers from such calls.1 Robocalls also provide critical, time-sensitive information—such as medical appointment reminders or fraud alerts—that many consumers want to receive. In this Order, we ensure that consumers can revoke consent for robocalls they no longer wish to receive while continuing to receive those they still want.2 We also modernize our rules to ensure that consumers have clear, simple, and automated ways to revoke consent while streamlining callers’ ability to process revocations. 2. Specifically, we modify our rules to allow callers to interpret a revocation request as applying only to the specific category of informational robocalls to which the revocation was directed, to allow callers to designate an exclusive means to revoke consent, and to amend the exemption from the consent requirement for financial institutions to allow them to more easily alert customers to fraudulent activity on their account. In addition, we delegate authority to the Consumer and Governmental Affairs * This document has been circulated for tentative consideration by the Commission at its September 30, 2026 open meeting. The issues referenced in this document and the Commission’s ultimate resolutions of those issues remain under consideration and subject to change. This document does not constitute any official action by the Commission. However, the Chairman has determined that, in the interest of promoting the public’s ability to understand the nature and scope of issues under consideration, the public interest would be served by making this document publicly available. The Commission’s ex parte rules apply and presentations are subject to “permit-but- disclose” ex parte rules. See, e.g., 47 CFR §§ 1.1206, 1.1200(a). Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules, including the general prohibition on presentations (written and oral) on matters listed on the Sunshine Agenda, which is typically released a week prior to the Commission’s meeting. See 47 CFR §§ 1.1200(a), 1.1203. 1 For purposes of this Order, the term “robocall” means any call made or text message sent using an automatic telephone dialing system (autodialer) or any call made using an artificial or prerecorded voice message. We refer to these communications collectively as “robocalls” unless otherwise specified. 2 The Telephone Consumer Protection Act (TCPA) requires any person making robocalls to residential telephone lines, wireless telephone numbers, or certain other specified lines or numbers, to obtain the recipient’s prior express consent absent an emergency purpose or an applicable exemption. See 47 U.S.C. § 227(b)(1)(A), (B). Federal Communications Commission FCC-CIRC 2609-05 Bureau (CGB) in consultation with the Enforcement Bureau to review our robocall rules3 to ensure that those rules are clear and easy to read. We also seek comment on updating various TCPA rules relating to the timeframe callers must honor revocation requests, requirements for two-way texting functionality, requiring a revoke all method, and the treatment of affiliates, as raised by the American Bankers Association, the National Consumer Law Center, and ACA International in a joint filing to the Commission.4 II. BACKGROUND A. Breadth of Revocation 3. TCPA Consent Order. In 2024, the Commission released the TCPA Consent Order, adopting various rules governing, and issuing clarifications relating to, the ability of consumers to revoke consent to receive robocalls.5 In so doing, the Commission adopted section 64.1200(a)(10), which requires in relevant part that “[i]f a called party uses any [reasonable] method to revoke consent, that consent is considered definitively revoked and the caller may not send additional robocalls and robotexts.”6 The Commission also clarified that, for those robocalls for which consent is required under the TCPA, “[o]nce that consent is revoked, the caller may no longer make robocalls or send robotexts to a called party absent an exemption to the consent obligation.”7 4. TCPA Further Notice of Proposed Rulemaking. In 2025, the Commission sought comment, among other issues, “on ways we can modify the requirement that a caller must treat an opt-out request made in response to one type of call to be an opt-out request for all types of calls or to modify it to give consumers greater control over their right to stop unwanted calls.”8 The Commission took this action in response to the request of several parties, including consumer groups and financial institutions, requesting that the Commission revisit this issue.9 3 See 47 CFR § 64.1200. 4 See Joint Letter from American Bankers Association, National Consumer Law Center, and ACA International to Brendan Carr, Chairman, FCC, CG Docket 02-278 (filed Jun. 30, 2026) (Joint Letter). 5 See Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG Docket No. 02-278, Report and Order and Further Notice of Proposed Rulemaking, 39 FCC Rcd 1988 (2024) (TCPA Consent Order). 6 47 CFR § 64.1200(a)(10). 7 TCPA Consent Order, 39 FCC Rcd at 1997, para. 29. On October 11, 2024, the Commission published an announcement in the Federal Register that the effective date of the amendments and new rules set forth in the TCPA Consent Order, including those contained in 47 CFR § 64.1200(a)(10), is April 11, 2025. See Federal Communications Commission, Strengthening the Ability of Consumers to Stop Robocalls, 89 Fed. Reg. 82518 (Oct. 11, 2024). CGB granted waivers delaying the effective date of the “revoke all” provision of section 64.1200(a)(10) until January 31, 2027. See Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG Docket No. 02-278, Order, 40 FCC Rcd 2395 (CGB 2025) (granting waiver delaying the effective date until April 11, 2026); Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG Docket No. 02-278, Order, DA 26-12 (CGB Jan. 6, 2026) (granting waiver extending the effective date until January 31, 2027). 8 See Advanced Methods to Target and Eliminate Unlawful Robocalls, Call Authentication Trust Anchor, Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Ninth Further Notice of Proposed Rulemaking in CG Docket No. 17-59, Seventh Further Notice of Proposed Rulemaking in WC Docket No. 17-97, Further Notice of Proposed Rulemaking in CG Docket No. 02-278, 40 FCC Rcd 8640, 8668, para. 101 (2025) (2025 TCPA FNPRM) (emphasis in original). The Commission sought comment on additional TCPA-related issues that are not addressed herein. Those issues remain pending for future consideration. 9 See Letter from Jonathan Thessin, Vice President and Senior Counsel, American Bankers Association, and Patrick Crotty, Senior Attorney, National Consumer Law Center, to Brendan Carr, Chairman, FCC, CG Docket No. 02-278 (filed Sept. 18, 2025). 2 Federal Communications Commission FCC-CIRC 2609-05 5. A broad consensus of commenters representing financial, health, utility, and consumer groups support modifying the “revoke all” rule.10 These commenters argue that the revoke all rule unduly restricts the ability of consumers to receive informational robocalls that they may want to receive by requiring the caller to interpret a request to revoke consent to one type of informational robocall as applicable to all types of informational robocalls from that caller.11 Numerous commenters also contend that the “revoke all” approach imposes significant compliance burdens on industries that must process opt-out requests across separate communications channels and platforms.12 No commenter opposes modification of the “revoke all” requirement, although some assert that any such revision be conditioned on the caller offering a means for revoking consent for all types of calls which require consent.13 B. Method of Revocation 6. In 2015, the Commission clarified that consumers who have provided prior express consent to receive robocalls may revoke their consent in “any reasonable manner that clearly expresses his or her desire not to receive further calls, and that the consumer is not limited to using only a revocation method that the caller has established as one that it will accept.”14 In 2024, the Commission confirmed that certain methods are “reasonable” to revoke consent.15 Specifically, the Commission adopted a rule making clear that any revocation requests made using: i) an automated, interactive voice or key press-activated opt-out mechanism in response to a robocall; ii) a response of “stop” or a similar, standard response message sent in reply to a text message, or iii) a website or telephone number provided by the caller to process opt-out requests constitute examples of a reasonable means to revoke consent.16 In addition, the Commission adopted a standardized list of specific words that may be used to revoke consent via a reply text message to ensure that such requests can be processed by automated systems that recognize the use of these commonly used words to revoke consent.17 7. In the 2025 TCPA FNPRM, the Commission sought comment on whether to permit callers to designate the exclusive means by which consumers may revoke prior express consent rather than requiring callers to honor all revocation requests made using any “reasonable means” and on whether there are less restrictive ways for consumers to revoke consent that avoid the potential ambiguity of the 10 See, e.g., ABA Comments at 9-12; AEP Comments at 6-9; APA Comments at 1; EEI Comments at 4-6; NCTA Comments at 7-8; NCLC Comments at 13-14; REACH Comments at 4-5; RILA Comments at 3-5; Twilio Comments at 14; Vistra Comments at 1-3; NCLC Reply Comments at 10. 11 See, e.g., ABA Comments at 9; ACA Comments at 18-19; AEP Comments at 6-7; CCC Comments at 3-4; H&R Block Comments at 4-5. 12 See, e.g., ECAC Comments at 2; EEI Comments at 5; NCTA Comments at 7; Twilio Comments at 14. 13 See, e.g., ABA Comments at 12 (noting that its “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 a means for the consumer to revoke consent with respect to all messages requiring consent”); ACA Comments at 20; EEI Comments at 6; NYSPSC Comments at 2; NCLC Comments at 14 (supporting revisions to allow “callers to construe a revocation as applying to only the type of message the prompted the revocation—but only if the call or message clearly and conspicuously discloses that the revocation will apply just to that type of message, and provides an automated method to revoke consent for all types of messages for which consent is required”); NCLC Reply Comments at 10. 14 See Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG Docket No. 02- 278, WC Docket No. 07-135, Declaratory Ruling and Order, 30 FCC Rcd 7961, 7999, para. 70 (2015) (2015 TCPA Declaratory Ruling). 15 See TCPA Consent Order, 39 FCC Rcd at 1991-92, paras. 11-13. 16 Id. at 1991, para. 11; see also 47 CFR § 64.1200(a)(10). 17 TCPA Consent Order, 39 FCC Rcd at 1991-92, para. 12. 3 Federal Communications Commission FCC-CIRC 2609-05 current “reasonable means” standard.18 In response, commenters representing a variety of industries and consumer groups support the proposal to allow callers to designate the exclusive means by which consumers may revoke consent instead of requiring callers to honor all revocations that are made by any reasonable method.19 Many of these commenters demonstrate that the requirement to process revocation requests submitted by any reasonable method creates significant operational challenges and costs.20 Several commenters also note that allowing the use of non-designated means to revoke consent often requires callers to process such requests manually which can result in delay and increased costs.21 C. Fraud Alert Exemption 8. In 2015, the Commission granted an exemption from the TCPA’s consent requirement to financial institutions when making certain informational robocalls to wireless telephone numbers.22 This exemption is limited to calls or text messages for the following four purposes: transactions and events that suggest a risk of fraud or identity theft, possible breaches of the security of customers’ personal information, steps consumers can take to prevent or remedy harm caused by data security breaches, and actions needed to arrange for receipt of pending money transfers.23 In granting this exemption, the Commission imposed certain conditions, including calling only those wireless numbers provided by the customer of the financial institution.24 9. In the 2025 TCPA FNPRM, the Commission sought comment on whether to eliminate the condition limiting financial institutions to calling only those wireless numbers provided by the consumer when making a fraud alert or similar call pursuant to the exemption in section 64.1200(a)(9)(iii).25 In response, commenters argue that the provided number condition significantly restricts the use of the exemption to make time-sensitive, fraud-related communications with customers.26 Both industry and consumer organizations request that we modify this exemption by allowing financial institutions to make exempted robocalls when the wireless number has been obtained from a reliable source.27 For example, 18 See 2025 TCPA FNPRM, 40 FCC Rcd at 8669, para. 103. 19 See, e.g., ABA Comments at 13-14; AEP Comments at 10-11; EEI Comments at 7; EIA Comments at 11; NADA Comments at 2-3; REACH Comments at 12; NCLC Reply Comments at 8-9 (supporting allowing callers to designate an exclusive method of revocation provided that it is “easy and automated” and disclosed “clearly and conspicuously” and proposing that callers must use one of three enumerated exclusive methods). 20 See, e.g., ABA Comments at 13-15 (under the existing rule banks must develop systems to recognize non- standardized revocation requests at substantial cost); EEI Comments at 5-6 (allowing unlimited revocation variations forces reliance on human resources, increases compliance risk, and reduces efficiency); IPA Comments at 3 (the current standard creates complexity resulting in operational failures and associated burden, time, and expense); Vibes Reply Comments at 4-6 (unduly burdens businesses); Joint Letter at 2. 21 See ABA Comments at 14; Vibes Reply Comments at 5-6. 22 See 2015 TCPA Declaratory Ruling, 30 FCC Rcd at 8024-28, paras. 129-39; 47 CFR § 64.1200(a)(9)(iii). 23 47 CFR § 64.1200(a)(9)(iii)(C). 24 Id. § 64.1200(a)(9)(iii)(A). 25 See 2025 TCPA FNPRM, 40 FCC Rcd at 8669-70, para. 105. 26 See, e.g., ABA Comments at 15-17; NCLC Comments at 16-17; NCTA Comments at 8-9; see also ECAC Comments at 2 (supporting a limited expansion of the financial institution exemption “but only under strict conditions to protect consumers and prevent abuse”). 27 See, e.g., ABA Comments at 16-17; NCLC Comments at 16-17; Letter from Margot Saunders, Senior Counsel, National Consumer Law Center, and Jonathan Thessin, Vice President and Senior Counsel, American Bankers Association, to Marlene Dortch, Secretary, FCC, CG Docket No. 02-278 at 3 (filed Apr. 23, 2020), https://www.fcc.gov/ecfs/document/1042401270989/1. The parties propose different versions of the first prong. The ABA Comments propose to use wireless telephone numbers provided by the “customer’s spouse.” ABA (continued….) 4 Federal Communications Commission FCC-CIRC 2609-05 when a telephone number is: 1) supplied by a spouse or other family member or by another cardholder on the account, 2) obtained when the consumer calls the institution (e.g., using Caller ID), or 3) included in records from accounts obtained from other financial institutions.28 In each of these circumstances, these commenters argue there is a high likelihood that the telephone number belongs to the customer, even though the customer did not directly provide the telephone number to the financial institution.29 III. DISCUSSION A. Ensuring Consumers Get the Calls They Want 10. We modify our rules to allow callers to interpret a revocation request as applying only to the specific category of informational robocalls to which the revocation was directed and not all robocalls.30 In so doing, we conclude that a requirement to treat a revocation request made in response to one type of informational robocall as applicable to all future robocalls unduly restricts consumers’ ability to receive other wanted calls. We emphasize that this specific modification affects only informational robocalls.31 11. We agree with a broad range of commenters representing various industries and consumer groups that the current “revoke all” rule does not align with consumer expectations and poses significant risks to the delivery of essential information.32 Specifically, we conclude that this requirement is overinclusive and may lead to unintended consequences that do not align with the consumer’s actual intent.33 For example, if a consumer revokes consent in response to payment reminders under the current rule interpretation the caller must stop all future robocalls on unrelated matters such as fraud alerts, multi- factor authentication, appointment reminders, or utility outage calls even if that was not the consumer’s will. The record suggests that this is often not consistent with the consumer’s intent.34 In fact, consumers may not even be aware that by revoking consent with respect to one category of informational messages, they are revoking consent to all messages from that caller.35 Comments at 16. The NCLC Comments propose to use wireless telephone numbers “supplied by a family member or other cardholder who has been explicitly authorized by that customer to be on the account.” NCLC Comments at 16-17. 28 See, e.g., NCLC Comments at 16-17. 29 Id. 30 We amend the text of section 64.1200(a)(10), (11), and (12) accordingly to reflect this modification. 31 For purposes of this proceeding, an “informational robocall” is a robocall that does not contain an advertisement or constitute telemarketing. See 47 CFR § 64.1200(f)(1), (13) (defining “advertisement” and “telemarketing,” respectively). 32 See, e.g., ABA Comments at 9-12; ACA Comments at 20; EEI Comments at 4-5; NCLC Comments at 13-14; NYSPSC Comments at 2; RESA Comments at 1-3; Wex Comments at 3. As discussed in more detail below, a few commenters condition support on providing a means to revoke consent to all types of messages. See infra para. 14. 33 See, e.g., ABA Comments at 9; ACA Comments at 18-19; CCC Comments at 3-4; NCTA Comments at 7-8; RMAI Comments at 3; Twilio Comments at 14; Vibes Comments at 13; Vistra Comments at 2. 34 See, e.g., ABA Comments at 10-11 (citing a survey indicating that 62 percent of respondents stated they are concerned that the “revoke all” rule will negatively impact them by their requiring their bank to stop sending all messages including fraud alerts); ACA Comments at 18-19; AEP Comments at 8; CCC Comments at 3-4; REACH Comments at 5. 35 See, e.g., ACA Comments at 18 (noting that consumers may inadvertently opt-out of critical communications); CCC Comments at 4 (contending that consumers may unknowingly opt-out of all communications when the intent is to opt-out of only a certain type); NCTA Comments at 7 (“revoke all” threatens to deprive consumers of desired communications); REACH Comments at 5; RESA Comments at 2 (noting risk that consumers inadvertently opt out of lifesaving communications). 5 Federal Communications Commission FCC-CIRC 2609-05 12. We conclude that the better reading of the TCPA permits consumers to avoid an all‑or‑nothing revocation by opting out of only those categories of informational robocalls they do not wish to receive while continuing to receive desired communications. This flexibility allows consumers greater control over robocalls while ensuring that critical, time-sensitive communications are not inadvertently stopped by the consumer. In addition, this approach addresses the concerns of utility companies that revocation requests will inadvertently extend to communications that they are legally required to make by limiting the scope of revocation only to the specific category of robocall to which they were directed.36 No commenter opposes this modification. 13. Currently some callers may also empower consumers to make more granular choices about the types of informational calls they wish to receive, including providing them with the option to revoke consent for all robocalls and text messages requiring consent. Some commenters request that we mandate a means by which consumers may revoke consent to all robocalls from a particular caller.37 One commenter expresses concern, however, with the potential compliance burdens entailed by requiring callers to provide a revoke all method.38 Therefore, we seek further comment in the attached Further Notice to inform the record on whether the benefits to consumers from requiring callers to provide a one- step means to revoke consent to all future robocalls outweigh the potential compliance burdens. 14. Revocation requests made in response to robocalls that contain an advertisement or constitute telemarketing revoke consent to all future robocalls containing an advertisement or that constitute telemarketing from that caller. Such calls constitute a specific category of communication for which there are no exemptions to the prior express consent requirement. As a result, consumers need only make a single revocation request to revoke consent to all future telemarketing robocalls from any caller. In that regard, we remind telemarketers that our rules require that a residential subscriber's do-not- call request shall apply to the particular entity making the call (or on whose behalf a call is made), as well as affiliated entities if the consumer reasonably would expect them to be included.39 B. Giving Consumers Clear, Simple, and Automated Ways to Revoke Consent 15. We modify our rules to allow callers to designate an exclusive means by which consumers may revoke consent instead of requiring callers to honor all revocation requests made “using any reasonable method,” as currently provided in section 64.1200(a)(10) of our rules.40 Specifically, we conclude that callers may designate any of the three methods currently described in the second sentence of section 64.1200(a)(10) as the exclusive means to make revocation requests.41 This approach adequately ensures that a simple, automated, easily understood method for revocation is readily available to consumers to revoke consent while streamlining the ability of callers to process such requests and reducing compliance burdens. In addition, this ensures that callers will not demand revocations to be made by unduly complex, difficult, or cumbersome methods that could prevent or deter consumers from revoking consent effectively. 16. As a result, callers may designate an exclusive revocation method that requires: (1) using 36 See Letter from Aryeh Fishman, Associate General Counsel, Edison Electric Institute to Marlene H. Dortch, Secretary, FCC, CG Docket No. 02-278, at 2-3 (filed Sept. 1, 2026) (proposing that a customer’s request to revoke consent for all future utility communications does not apply to legally or regulatorily required utility communications unless made directly in response to such communications) (EEI Ex Parte). 37 See, e.g., NCLC Comments at 17; NYSPCS Comments at 2. 38 See REACH Reply Comments at 4-5. 39 See 47 CFR § 64.1200(d)(5). 40 47 CFR § 64.1200(a)(10). 41 See id. We clarify that callers can designate one or more of these three revocation methods. See, e.g., REACH Comments at 13-14. 6 Federal Communications Commission FCC-CIRC 2609-05 an automated, interactive voice or key-press activated opt-out mechanism in response to a robocall, (2) using specific standardized words in response to an incoming text, and/or (3) using a website or telephone number provided by the caller to process opt-out requests, so long as the caller clearly and conspicuously discloses the designated method for revoking consent on the call or in the text. Callers that designate any of these three exclusive means to revoke consent will not be required to process revocation requests made by any other means. Any caller that does not designate one of the methods listed in section 64.1200(a)(10) as the exclusive means to revoke consent must continue to process revocation requests when made in any reasonable manner.42 17. We agree with both industry and consumer groups that the designated use of these methods ensures that consumers can easily revoke consent while allowing callers to use cost effective, automated systems to process all incoming revocation requests.43 This approach also provides clarity by eliminating the need to determine on a case-by-case basis whether a “reasonable means” is used to revoke consent.44 We also agree with industry and consumer groups who contend that callers that designate an exclusive method to revoke consent should disclose that method on calls and in messages.45 This ensures that callers inform consumers of the designated revocation method.46 We therefore decline the request to allow callers to determine when and how to inform customers of the designated method.47 In addition, we agree with industry and consumer groups that allowing callers to designate an automated revocation method as the exclusive means to revoke consent will incentivize more callers to make available such revocation methods and avoid delays inherent in manually processing revocation requests that result when made by non-designated methods.48 We disagree with the commenter who argues that callers that are regulated by another agency when communicating with consumers should be allowed to designate any such revocation method established by that agency’s regulations as the exclusive means to revoke consent.49 While certain callers may be subject to such requirements, the record in this matter does not provide sufficient confirmation of the consumer protections afforded by these alternative methods to conclude that callers can designate such methods as the exclusive method for revoking consent. 18. We emphasize that this rule modification does not alter the existing opt-out methods specified in our rules for calls made pursuant to an exemption or that include an advertisement or constitute telemarketing.50 For example, section 64.1200(b)(3) of our rules requires calls made pursuant to an exemption in section 64.1200(a)(3)(ii)-(v) or that use an artificial or prerecorded voice that introduces an advertisement or constitutes telemarketing to provide an automated, interactive voice- 42 We have amended section 64.1200(a)(11) accordingly. See Appendix A. 43 See, e.g., ACA Comments at 21-22; NCLC Comments at 12-13; NCLC Reply Comments at 8-9. 44 See EEI Comments at 7-8; EIA Comments at 11 (contending that the “reasonable means” standard “has enabled a tactic where litigants intentionally bypass clear, simple, and automated opt-out instructions in favor of ambiguous phrases designed to evade recognition, thereby manufacturing lawsuits”); IPA Comments at 2; REACH Comments at 12; ACA Reply Comments at 8. 45 See, e.g., Joint Letter at 3. 46 We note that telemarketers and exempted callers must inform call recipients of the designated revocation methods on the call or message. See, e.g., 47 CFR § 64.1200(a)(9), (b)(3). 47 See EEI Ex Parte at 4. 48 See ABA Comments at 14; NCLC Comments at 12. 49 See ACA Comments at 22-23 (citing regulations for debt collection calls that require consumers to notify the caller in writing that they want to stop future calls). 50 See, e.g., 47 CFR § 64.1200(a)(3)(ii)-(v), (a)(9), (b)(3). 7 Federal Communications Commission FCC-CIRC 2609-05 and/or key press-activated opt-out mechanism to make a do-not-call request.51 Callers subject to these requirements must comply with these obligations and utilize the opt-out method specified in our rules. C. Revisiting Fraud Alert Restrictions 19. We amend the exemption for financial institutions to initiate certain informational robocalls to wireless numbers without prior consent by modifying the condition limiting financial institutions to communicating only with those customers using a telephone number they provided directly to that financial institution.52 Specifically, we agree with commenters that exempted communications should be allowed when the wireless number is obtained from a reliable source.53 We conclude that a “reliable source” in this context includes a telephone number: i) supplied by a spouse or other family member who is authorized to be on the account; ii) obtained when the customer calls the institution; or iii) included in the records obtained from another financial institutions.54 20. We agree with commenters that the current condition limiting financial institutions to communicating only with those customers who have provided their telephone numbers to that financial institution unduly restricts the ability to communicate important, often time-sensitive information to customers.55 This includes communications related to transactions and time sensitive events informing consumers of a risk of fraud or identity theft. For similar reasons, we grant ABA’s 2015 petition for reconsideration to the extent that it requests that the Commission revisit the provided number condition.56 21. We conclude that this modification enhances the ability of financial institutions to communicate critical information under the exemption without infringing upon consumer privacy rights. In this regard, we encourage financial institutions to make use of resources such as the Reassigned Numbers Database (RND) to prevent calls being misdirected from someone who previously held that phone number.57 In addition, we emphasize that financial institutions making use of this exemption must honor opt-out requests from consumers to ensure that they are calling only those parties that wish to 51 See 47 CFR § 64.1200(b)(3). Similarly, section 64.1200(a)(9) requires calls made to wireless numbers pursuant to an exemption to offer certain specific opt-out methods to the called party such as automated, interactive voice or key press, toll free numbers, or replying “stop” in response to text messages. See id. § 64.1200(a)(9)(i)(G), (ii)(E), (iii)(G), (iv)(G). 52 See 47 CFR § 64.1200(a)(9)(iii)(A). This exemption contains additional conditions such as a limitation on the number of exempted calls and messages that can be made to a called party. One commenter suggests that the fraud alert exemption be extended to cover “other important customer communications” such as notifications that tax returns have been rejected. We conclude, however, that this request is vague and beyond the limited scope of the 2025 TCPA FNPRM which sought comment on eliminating the provided number condition. See H&R Block Comment at 9. For similar reasons, we decline to address the request to expand the fraud alert exemption beyond financial institutions to other businesses including communications providers. See NCTA Comments at 9. 53 See ABA Comments at 16; NCLC Comments at 16-17. 54 See, e.g., ABA Comments at 16-17; NCLC Comments at 16-17. We note that these commenters vary on the exact description of the first prong, and our rule reflects a combination of ABA’s proposal to use the spouse as a reliable source and NCLC’s proposal to use “a family member or other cardholder who has been explicitly authorized by that customer to be on the account.” We believe this approach provides flexibility to make reasonable use of the exemption while ensuring that the number is provided by a reliable source. 55 See ABA Comments at 16; NCLC Comments at 16-17. 56 See Petition for Reconsideration of American Bankers Association, CG Docket No. 02-278, WC Docket No. 07- 135 (filed Aug. 10, 2015). 57 Callers and texters can use the RND to determine whether a telephone number may have been reassigned following a specific date so they can avoid potential liability for calling consumers who have not consented to these calls. See 47 CFR § 64.1200(m). 8 Federal Communications Commission FCC-CIRC 2609-05 receive such communications.58 When combined with other conditions imposed on this exemption, such as a numerical limitation on the number of calls and messages that can be made pursuant to the exemption, we believe that modifying this condition does not adversely affect consumer privacy interests while promoting the ability of financial institutions to communicate important information to their customers and others authorized on the account.59 D. Improving the Organization and Readability of the Robocall Rules 22. We delegate authority to CGB in consultation with the Enforcement Bureau to review the rules contained in section 64.1200 to ensure that those rules are clearly organized and comprehensible, and to invite comment at a later date on proposed changes to make these rules more transparent and easier to understand.60 This rule section contains numerous robocall and call blocking-related rules adopted and revised over the last three decades as part of our ongoing effort to implement the TCPA and protect consumers from illegal robocalls. As a result, these rules have grown increasingly lengthy and dense. The substance of these rules will not be changed on delegated authority, instead the goal is to recast them where appropriate in plain language so as to give regulated entities, as well as the broader public, a better grasp of what is required, what is permitted, and what is prohibited under these rules. We make clear that substantive changes to these rules are excluded from this delegation of authority. We believe such revisions to make the rules easier to understand can enhance compliance, reduce transaction costs, and make it easier to identify and report violations. E. Effective Date 23. The revised rule amendments contained herein become effective 30 days after Federal Register publication.61 As a result, the rule modification to section 64.1200(a)(10) will go into effect at that time and supersede the delayed effective date of the relevant portion of that rule that was previously extended to January 31, 2027.62 F. Cost and Benefit Analysis 24. Although robocalls are most commonly associated with illegal calls that defraud and annoy consumers, and are consistently a top consumer complaint, the term includes a wide array of calls, many of which are legal and benefit consumers. For example, robocalls are used to communicate time sensitive information such as fraud alerts, appointment reminders, school closings, power outages, and public safety notifications. The efficient provision of such information via robocalls provide consumers with substantial financial, health, and safety benefits by ensuring that consumers receive critical information that allows them to take time-sensitive actions in response to such communications. As a result, the right to grant and revoke consent to receive robocalls is fundamental to empowering consumers to manage those calls they wish to receive. Unduly restricting a consumers’ ability to receive the calls they wish to receive is detrimental to this goal. 25. The rule modifications contained herein enhance the ability of consumers to decide which 58 See 47 CFR § 64.1200(a)(9)(iii)(G), (H) (specifying opt-out methods and requiring financial institutions to honor opt-out requests made in response to an exempted call or message “immediately”). 59 Id. § 64.1200(a)(9)(iii)(F) (a financial institution may initiate no more than three messages (whether by voice call or text message) per event over a three-day period for an affected account). 60 Id. § 64.1200. We anticipate that CGB will seek comment on any such proposals in an upcoming Public Notice. 61 The Commission will release a Public Notice indicating the specific effective date when that information becomes available. 62 We note that the Office of Management and Budget has approved the Commission’s information collection requirements associated with the TCPA including all the consent-related rules contained in the 2024 TCPA Consent Order. Notice of Office of Management and Budget Action, OMB Control No. 3060-0519, available at https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202408-3060-009. 9 Federal Communications Commission FCC-CIRC 2609-05 robocalls that they wish to receive by ensuring that they have easy access to simple methods to revoke consent for those robocalls that they do not wish to receive while allowing them to continue receiving important information from financial institutions, health care providers, and utilities. While some consumers may be required under our modified rules to make more than one revocation request in response to informational robocalls, we believe this burden is minimal and offset by the benefits of the approach adopted herein. In so doing, we also streamline existing requirements such as by allowing callers the option to designate the exclusive method to be used for revoking consent to ensure that such request can be efficiently processed by automated means rather than requiring callers to process all revocation requests made in a reasonable manner. We impose no new compliance obligation. We therefore conclude that benefits of the rule modifications contained herein to both consumers and industry, as supported by a wide variety of commenters including consumer groups, financial institutions, health care organizations, and utilities, substantially outweigh any costs. G. Legal Authority 26. The Commission has legal authority to take the actions contained herein pursuant to sections 151-154, and section 227 of the Communications Act of 1934, as amended.63 IV. FURTHER NOTICE OF PROPOSED RULEMAKING 27. While this Order modifies our consent revocation framework to give consumers clearer control over the calls they wish to receive, we now seek further comment on additional revisions that can ensure these rules continue to evolve with changes in technology and industry practices. A. Joint Letter 28. On June 30, 2026, American Bankers Association, National Consumer Law Center, and ACA International filed a joint letter expressing concerns with the Commission’s TCPA Consent Order and proposing additional revisions to our TCPA rules.64 As discussed in greater detail below, we seek comment on these proposals including reducing the timeframe to honor revocation requests, requiring two-way texting to facilitate revocation requests made in response to text messages, requiring a “revoke all” method, and how revocation requests should apply to affiliates, separate lines of business, or divisions of entities of which such businesses are a part.65 B. Timeframe for Honoring Revocation Requests 29. We seek comment on whether to reduce the timeframe for callers to honor revocation requests. Consumers are understandably frustrated when they continue to receive robocalls after revoking consent. Such delays also undermine a consumer’s right to determine which robocalls that they wish to receive under the privacy protections afforded by the TCPA. Our rules currently provide that callers must honor revocation of consent requests within a reasonable time from the date that the request is made, not to exceed ten business days after receipt of the request.66 In adopting this timeframe, the Commission noted that advances in technology over time, including the use of automated and interactive technologies, makes the processing of revocation requests more efficient and timely and reserved the right to adjust this timeframe as necessary.67 30. Because callers may now designate an exclusive, automated means by which consumers must revoke consent, we seek comment on whether they can now process revocation requests more 63 See 47 U.S.C. §§ 151-154, 227. 64 See Joint Letter at 1-2, 65 See generally Joint Letter; see also EEI Ex Parte (addressing various proposals contained in the Joint Letter). 66 See 47 CFR §§ 64.1200(a)(10), (d)(3). 67 See TCPA Consent Order, 39 FCC Rcd at 1994, para. 20. 10 Federal Communications Commission FCC-CIRC 2609-05 quickly and efficiently. As a result, we seek comment on whether to reduce the maximum timeframe for honoring revocation requests. For example, the Joint Letter suggests reducing the deadline to seven business days unless the caller demonstrates that processing a revocation beyond seven business days is reasonable.68 Is that a reasonable timeframe for callers to process revocation requests? Should the timeframe vary between those callers that designate an exclusive means to revoke consent and those that do not? Would varying timeframes result in consumer confusion? We seek comment on the cost and benefits to reduce the maximum timeframe for honoring revocation requests including ways to minimize any burdens on smaller entities subject to this obligation. We seek comment on these and any other issues relevant to this issue. C. Two-Way Texting 31. We seek comment on whether to eliminate the provision from section 64.1200(a)(10) of our rules that allows text senders to use a texting protocol that does not allow consumers to revoke consent by reply text.69 Our rules currently permit text senders to utilize a texting protocol that does not allow for reply texts when the text sender: (1) provides a clear and conspicuous disclosure in each text to the consumer that two-way texting is not available due to technical limitations of the texting protocol; and (2) clearly and conspicuously provides in each text a reasonable alternative method for a consumer to revoke consent, such as a telephone number or website.70 32. In the 2024 TCPA Consent Order, the Commission concluded that while there is no mandate that texting parties transmitting an autodialed text message must provide consumers with any specific means to revoke consent, such as through reply texts, that two-way texting is a reasonable and widely recognized means for text recipients to revoke prior express consent.71 In the Joint Letter, ABA, NCLC, and ACA International propose a rule amendment that would remove the provision from our rules that allows text senders to use one-way texting protocols by providing an alternative means in each text to revoke consent.72 33. We seek comment on whether to require senders of text messages subject to section 64.1200(a)(10) to provide recipients with the ability to use reply texts to revoke consent. In that regard, we seek comment on the extent to which text senders currently use texting protocols that do not allow for reply texts. Are one-way texting protocols used primarily for informational and notification purposes or are they also used for telemarketing and advertising? Should we consider allowing one-way texting for informational messages and require two-way texting only on text messages that include an advertisement or telemarketing? To what extent would requiring the use of two-way texting protocols enhance the ability of text recipients to more easily revoke consent to unwanted text messages by replying to the text? Conversely, to what extent would eliminating the ability of text senders to use one-way texting protocols increase compliance burdens or interfere with the ability to communicate with consumers? We seek comment on these and any other related issues including how we might minimize any compliance burdens for small entities as well as public institutions, such as schools that currently use one-way texting services. D. Revoke All Method 34. We seek comment on whether callers should be allowed to treat a revocation request as applying to the type of call that prompted the revocation only if the caller provides a “method to revoke 68 See Joint Letter at 3; see also EEI Ex Parte at 5-6 (generally supporting the seven business day processing framework). 69 See 47 CFR § 64.1200(a)(10). 70 Id. 71 See TCPA Consent Order, 40 FCC Rcd at1992, para. 14. 72 See Joint Letter at 3 (proposing revised section 64.1200(a)(10)). 11 Federal Communications Commission FCC-CIRC 2609-05 consent for all types of messages for which consent is required.”73 We also seek comment on whether we should require any such “revoke all” mechanism to be automated, and, if so, what specific forms such an automated mechanism should take. In light of our rule change allowing callers to interpret a revocation request as applying only to the specific category of informational robocalls to which the revocation was directed, we seek comment on whether consumers would benefit from a one-step option to stop all future robocalls.74 If so, we seek comment on what methods should be mandated and how such requirements could be designed to minimize compliance burdens, including on small entities. We also seek comment on EEI’s request for clarification that revocation requests apply only to the telephone number for which consent has been revoked rather than extend to all telephone numbers associated with a customer’s account.75 In that regard, we seek comment on whether this request is consistent with the TCPA’s reference to obtaining consent of the “called party” and Commission precedent.76 35. Alternatively, we seek comment on whether the potential compliance burdens and risk of inadvertent revocation of consent to calls that they may wish to receive outweigh any such benefits and therefore should counsel against adopting such a requirement. To what extent does our clarification that revocation requests made in response to robocalls with an advertisement or that constitute telemarketing revoke consent to all similar robocalls from that caller address concerns that consumers will be burdened with multiple revocation requests? We seek comment on whether limiting this situation to informational calls adequately mitigates those concerns. In addition, we note that one commenter opposes any requirement to provide a method to revoke consent to all calls arguing that such a requirement is not required by the TCPA and would impose significant burdens on callers.77 To the extent that the Joint Letter proposes revocation methods that effectively treat a customer’s failure to respond to communications intended to clarify a revocation request as a revocation of consent for all future robocalls, we seek comment on concerns that this is an overly broad approach that may not reflect customer intent.78 We seek comment on these and any other related issues in this context. E. Affiliates and Separate Lines of Businesses or Divisions 36. We seek comment on whether further specificity is useful to clarify the application of the TCPA’s consent and revocation requirements where an entity operates through separate affiliates, lines of business, or divisions. We note that our current rules for exempted calls to residential telephone lines and telemarketing calls provide that “[i]n the absence of a specific request by the subscriber to the contrary, a residential subscriber's do-not-call request shall apply to the particular entity making the call (or on whose behalf a call is made), and will not apply to affiliated entities unless the consumer reasonably would expect them to be included given the identification of the caller and (for telemarketing calls) the product being advertised.”79 37. We seek comment on whether we should modify this existing standard or provide more 73 See NCLC Comments at 14; NCLC Reply Comments at 8; see also ABA Comments at 12; Joint Letter at 3 (suggesting that “the caller or sender inform[] the recipient of an option, including a separate call or message, to revoke consent with respect to all calls and text messages requiring consent”); NYSPSC Comments at 2. 74 We note that callers can make available a one-step method to revoke consent to all robocalls and text messages and inform recipients of these methods even absent any mandate to do so. 75 See EEI Ex Parte at 4. 76 See, e.g., 47 U.S.C. § 227(b)(1); see also TCPA Consent Order, 39 FCC Rcd at 1998, para. 32 (indicating that if a called party has revoked consent, the caller no longer has consent to make further robocalls or robotexts to that called party absent instructions to the contrary from the consumer). 77 See REACH Reply Comments at 4-5. 78 See EEI Ex Parte at 3-4. 79 See 47 CFR § 64.1200(d)(5). 12 Federal Communications Commission FCC-CIRC 2609-05 specific guidance. If so, we seek comment on the form of such guidance. We also seek comment on whether this rule or a modified rule should be expanded to encompass all robocalls rather than limited to exempted and telemarketing calls. In that regard, we note that financial and consumer groups have suggested that we adopt a new rule governing affiliates and separate lines of businesses or divisions.80 We seek comment on these and any other issues related to this matter. F. Other 38. We seek comment on whether there are any additional changes that we should consider to our rules that govern revocation of consent in light of changes in technology and industry practices including any proposals contained in the Joint Letter or EEI Ex Parte not referenced above. For example, we note that the Joint Letter proposes to reduce the list of standardized words that can be used to revoke consent,81 eliminates the rebuttable presumption analysis contained in the current section 64.1200(a)(11) to determine whether a reasonable revocation method has been used when a caller has not designated an exclusive means to revoke consent, and allow callers to make a confirmation call in response to a revocation request within a reasonable time, not to exceed the end of the next business day.82 We seek comment on these and any other issues relevant to this matter. V. PROCEDURAL MATTERS A. Paperwork Reduction Act Analysis 39. This document may contain non-substantive modifications to approved information collections. Any such modifications will be submitted to the Office of Management and Budget (OMB) for review pursuant to OMB’s non-substantive modification process. In addition, therefore, it does not contain any new or modified information collection burden for small business concerns with fewer than 25 employees, pursuant to the Small Business Paperwork Relief Act of 2002, 44 U.S.C. § 3506(c)(4). 40. This FNPRM may contain proposed new or modified information collection requirements. The Commission, as part of its continuing effort to reduce paperwork burdens, invites the general public and OMB to comment on these information collection requirements, as required by the PRA. In addition, pursuant to the Small Business Paperwork Relief Act of 2002, 44 U.S.C. § 3506(c)(4), we seek specific comment on how we might further reduce the information collection burden for small business concerns with fewer than 25 employees. B. Regulatory Flexibility Act Analysis 41. Regulatory Flexibility Act. The Regulatory Flexibility Act of 1980, as amended (RFA),83 requires that an agency prepare a regulatory flexibility analysis for notice and comment rulemakings, unless the agency certifies that “the rule will not, if promulgated, have a significant economic impact on a 80 See Joint Letter at 4. These parties suggest a new section 64.1200(a)(13) to read as follows: “(13) Affiliates and separate lines of business or divisions. If an entity operates through separate affiliates, lines of business or divisions, [and one of its affiliates, lines of business, or divisions] obtains a separate consent and holds itself out to the called party throughout all calls and texts with the called party as that particular affiliate, line of business or division rather than as the entity of which such affiliate, line of business or division is a part, then such affiliate, line of business or division will be deemed a separate caller or text sender for the purposes of this section.” Id. (emphasis in original; bracketed language added to clarify meaning). 81 See also EEI Ex Parte at 5 (indicating that the Commission should “recognize additional standardized revocation keywords and customer preference tools”). 82 See Joint Letter at 3-4 (revisions contained in sections 64.1200(a)(10)(ii), (11) and (12)). 83 5 U.S.C. §§ 601 et seq., as amended by the Small Business Regulatory Enforcement and Fairness Act (SBREFA), Pub. L. No. 104-121, 110 Stat. 847 (1996). 13 Federal Communications Commission FCC-CIRC 2609-05 substantial number of small entities.”84 Accordingly, the Commission has prepared a Final Regulatory Flexibility Analysis (FRFA) concerning the possible impact of the rule and policy changes contained in this Report and Order on small entities. The FRFA is set forth in Appendix B. 42. The Commission has also prepared an Initial Regulatory Flexibility Analysis (IRFA) concerning the potential impact of rule and policy change proposals on small entities in the FNPRM. The IRFA is set forth in Appendix C. The Commission invites the general public, in particular small businesses, to comment on the IRFA. Comments must be filed by the deadlines for comments on the FNPRM indicated on the first page of this document and must have a separate and distinct heading designating them as responses to the IRFA. C. Congressional Review Act 43. The Commission has determined, and the Administrator of the Office of Information and Regulatory Affairs, Office of Management and Budget, concurs, that this rule is “non-major” under the Congressional Review Act, 5 U.S.C. § 804(2). The Commission will send a copy of this Report and Order to Congress and the Government Accountability Office pursuant to 5 U.S.C. § 801(a)(1)(A). D. Filing Requirements—Comments and Replies 44. Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, interested parties may file comments and reply comments on or before the dates indicated on the first page of this document. Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS).85 Electronic Filers: Comments may be filed electronically using the Internet by accessing the ECFS: https://www.fcc.gov/ecfs. • Paper Filers: Parties who choose to file by paper must file an original and one copy of each filing. o Filings can be sent by hand or messenger delivery, by commercial courier, or by the U.S. Postal Service. All filings must be addressed to the Secretary, Federal Communications Commission. o Hand-delivered or messenger-delivered paper filings for the Commission’s Secretary are accepted between 8:00 a.m. and 4:00 p.m. by the FCC’s mailing contractor at 9050 Junction Drive, Annapolis Junction, MD 20701. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes and boxes must be disposed of before entering the building. o Commercial courier deliveries (any deliveries not by the U.S. Postal Service) must be sent to 9050 Junction Drive, Annapolis Junction, MD 20701. o Filings sent by U.S. Postal Service First-Class Mail, Priority Mail, and Priority Mail Express must be sent to 45 L Street NE, Washington, D.C. 20554. • People with Disabilities. To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an email to fcc504@fcc.gov or call the Consumer and Governmental Affairs Bureau at (202) 418-0530. E. Ex Parte Rules 45. The proceeding this FNPRM initiates shall be treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules.86 Persons making ex parte presentations 84 Id. § 605(b). 85 See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998). 86 47 CFR § 1.1206. 14 Federal Communications Commission FCC-CIRC 2609-05 must file a copy of any written presentation or a memorandum summarizing any oral presentation within two business days after the presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex parte presentation was made, and (2) summarize all data presented and arguments made during the presentation. If the presentation consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s written comments, memoranda, or other filings in the proceeding, the presenter may provide citations