What Does ‘Any Reasonable Means’ Mean? NAFCU Joins Other Groups in Urging Better Definition

WASHINGTON— The legal standard of “any reasonable means” to revoke consent when it comes to consent is difficult to interpret for callers and encourages legal action, according to NAFCU and a number of other groups.

The organizations offered their feedback and recommendations in a letter to the Federal Communications Commission (FCC) in response to its notice of proposed rulemaking to codify its 2015 ruling that allows consumers to revoke consent for robocalls or robotexts through “any reasonable means.”

In the letter, the trade groups urged the FCC to express that “a business and its customer may contractually agree to specific and reasonable methods by which the customer may revoke consent to receive autodialed or prerecorded calls or text messages.”

Additional Arguments

In addition, the groups argued that revocation of consent should only apply to the type of information in the original text or call.

“To avoid consumer harm, it is critical that businesses not be compelled to apply a customer’s revocation request to a broader category of messages than the customer intends,” wrote the trades.

The groups also requested a six-day deadline to process revocation requests and an 18-month implementation period for the rule.

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