ETA Submits Comments to the FCC on Interpretation of the Telephone Consumer Protection Act in Light of the D.C. Circuit’s ACA International Decision

The Electronic Transactions Association (“ETA”) submits these comments in response to the Federal Communications Commission’s (“FCC” or “Commission”) Consumer and Governmental Affairs Bureau’s May 14, 2018 Notice seeking Comment on Interpretation of the Telephone Consumer Protection Act in Light of the D.C. Circuit’s ACA International Decision, CG Docket Nos. 18-152, 02-578 (“Notice”) and in further support of the May 3, 2018 Petition for Declaratory Ruling filed by ETA and various other entities in CG Docket No. 02-578.

ETA is the leading trade association for the payments industry. Its membership spans the breadth of that industry to include independent sales organizations, payments networks, financial institutions, transaction processors, mobile payments products and services, payments technologies, equipment suppliers, and online small business lenders. ETA’s comments are intended to assist the Commission in its evaluation of common sense approaches to interpreting the Telephone Consumer Protection Act (“TCPA”) to protect communications between legitimate companies and their customers while at the same time achieving the original goal of the TCPA: to combat unlawful and intrusive telemarketing calls. The two goals go hand-in-hand, especially given the widespread litigation abuse that continues under the TCPA, and the impact it is having and will continue to have on business-customer relationships absent common sense interpretations and common sense enforcement of the statute.

Read the Full Comments Here.