Advocacy

FCC Modernizes TCPA "Revoke All" Rules, Providing Greater Flexibility to CU Member Communications

The Federal Communications Commission (FCC) has approved changes to its Telephone Consumer Protection Act (TCPA) rules that will give credit unions and other financial institutions greater flexibility to continue sending important account and fraud-related communications to members.

The FCC’s final order modernizes its “revoke all” requirements. Under the previous rule, when a consumer revoked consent to receive one type of automated call or text, that request could apply broadly to other communications requiring consent.

For credit unions, that created the potential for members who opted out of one category of messages to also stop receiving unrelated communications, including fraud alerts, multi-factor authentication messages and account updates.

Under the FCC’s revised approach, an opt-out request for informational calls and texts will generally apply only to the specific category of communications to which the request was directed. That means a member opting out of one type of informational message would not automatically be considered to have revoked consent for other categories of important communications.

The final order also allows callers to designate an exclusive method for consumers to revoke prior express consent. Depending on the communication, that could include an automated voice or key-press option, a standardized response to a text message, or a clearly disclosed website or telephone number for processing opt-out requests.

Additionally, the FCC expanded an exemption for certain informational calls from financial institutions. Credit unions will be able to use phone numbers obtained from reliable sources in certain circumstances, including numbers provided by an authorized spouse or family member, obtained when a member contacts the credit union, or included in records received from another financial institution.

Why It Matters for Credit Unions

The changes are particularly significant as credit unions continue working to protect members from increasingly sophisticated fraud and scams.

By narrowing the scope of a consumer’s revocation request, the new rules can help credit unions maintain critical communications with members even when they choose to opt out of other types of messages. The FCC’s changes also provide greater clarity around how opt-out requests can be submitted and give financial institutions additional flexibility to reach members when important account or fraud-related information needs to be communicated.

The order will take effect 30 days after publication in the Federal Register, superseding the previously delayed Jan. 31, 2027, effective date for the relevant portion of the rule.