Debt Collectors Push FCC To Shed Consumer Contact Rules

Law360 (June 11, 2025,) — Debt collectors are adding their two cents to the Federal Communications Commission’s request for unnecessary regulations that should be eliminated, calling on the agency to eliminate an upcoming rule that would make it easier for individuals to stop future robocalls and texts.

In a letter the commission filed last week and published Monday, a group of debt collection agencies and their trade associations gave public notice of a meeting held June 4 with FCC Chair Brendan Carr’s legal advisor, in which they urged the agency to add the “revoke all” rule to the list of regulatory fat that should be cut from the commission’s rolls.

Issued under the Telephone Consumer Protection Act, or TCPA, the rule would extend an individual’s consent revocation to apply to all future robocalls and messages from the sender entity, even if future communications are unrelated to the original messages in their subject matter.

In April, the FCC acquiesced to requests from financial institutions and delayed the rule’s implementation for a year, pushing the date on which it will take effect to April 11, 2026. In its order, the agency said that a “limited delay is necessary to provide sufficient time for affected parties to process revocation requests received across different business units.”

But now, the debt collectors — led by ACA International, or the Association of Credit and Collection Professionals; American Profit Recovery; Collection Bureau Services and Encore Capital Group — are calling for the commission to do away with the rule entirely.

“ACA noted the broad support for reviewing the Commission’s regulations implementing the TCPA, including eliminating the ‘revoke all’ rule,” the collectors said of their meeting.

The filing comes in response to a public notice from the agency issued in March, in which the newly Republican-controlled FCC called for suggestions of regulations that should be cut on its “Delete, Delete, Delete” docket. The agency was quickly flooded with recommendations from broadcasters, satellite companies, wireless providers and even prison phone companies offering up rules they would like the commission to do away with.

In a lengthier filing from April, ACA International called the rule “sweepingly broad,” and argued it would result in “consumers inadvertently opting out of important informational calls.” According to the industry group, consumers frequently have overdue payments on several accounts. However, by instructing a collector to stop texting or calling regarding one account, they would also prevent the collector from reaching out about others, even if the accounts are with unrelated creditors.

“This puts consumers in jeopardy because they may be deprived of the opportunity to resolve outstanding debts, leaving them exposed to litigation or worsening the consumer’s credit rating,” ACA International said.

But if Carr’s own vote on the “revoke all” rule is any indication, the debt collectors may have a tough time getting it canned altogether. Carr supported the rule’s adoption last year, saying that it struck “a better balance” than the “amorphous standard” for consent revocation created under the agency’s earlier rule. However, he did not provide a full statement detailing his support.

Representatives for Carr did not immediately respond to Law360’s request for comment on the new filing on Wednesday.

The end of the “revoke all” rule is not the only regulatory change the debt collectors are targeting. They also called for the agency to restore the “established business relationship” exemption and extend it to wireless numbers. Under the exemption, entities with previously established relationships with individuals did not need consent for telemarketing robocalls to their home phones. The exemption was removed in 2012 for landlines, but now collectors want it reinstated and extended to mobile phones.

“In all cases, the existence of [an] established business relationship creates a reasonable expectation on the consumer’s part that they may receive a communication,” the collectors said in their April filing. “This is particularly true for third party debt collection calls because the consumer is typically notified that their debt has been transferred to collection, creating the expectation of receiving communications from the third party.”

–Additional reporting by Nadia Dreid and Christopher Cole. Editing by Vaqas Asghar.

Read more at: https://www.law360.com/articles/2352021/debt-collectors-push-fcc-to-shed-consumer-contact-rules?copied=1