RILA Comments to ACA Decision
On Wednesday, June 13, 2018, RILA submitted comments to the FCC in response to its Interpretation of the Telephone Consumer Protection Act in Light of D.C. Circuit’s ACA International Decision Request for Comment. In short, the comments vocalized RILA's support for the development of reasonable, understandable, and administrable rules for telephonic interactions between retailers and consumers, and seek changes to four of the Commission’s prior TCPA decisions:
The elaboration of the characteristics of an autodialer;
The interpretation of the term “called party” and its rules regarding reassigned numbers;
The approach to how a called party can revoke his or her prior consent to be called; and
The adoption of conflicting healthcare exemptions that treat important notifications such as prescription refill reminders differently based on whether the patient happens to rely on a wireless phone or a landline.