FCC Issues Two Important TCPA Decisions

The Federal Communications Commission (FCC) has adopted two Telephone Consumer Protection Act (TCPA) decisions that significantly impact compliance obligations for a wide range of organizations that make or facilitate voice calls or text messages to consumers. In the first order, the Cargo Airline Association (CAA), represented by Hogan Lovells, obtained a first-of-its-kind exemption from the TCPA's "prior express consent" restriction on autodialed and prerecorded telephone calls and text messages to wireless telephone numbers. In a second decision granting in part a petition filed by GroupMe, Inc., the FCC clarified that a consumer's "prior express consent" to receive autodialed text messages on his or her wireless telephone number may be obtained through and conveyed by an intermediary.

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