October 26, 2020 — Comments

We applaud the Commission’s proposal to provide consumers with the right to opt out of all exempted prerecorded calls. The Commission is required by the TRACED Act to establish numerical limits for all exempted calls, and we recommend that the numerical limit for prerecorded calls to a residential line that are exempted from the requirement for consent be limited as follows:

  • Transactional calls that are related to debt collection should be limited to three calls per thirty days per person called.
  • Other transactional calls to confirm or complete a transaction that the called party has initiated, the limit should be two calls per action that the called party needs to take.
  • Prerecorded calls that are designed simply to provide information should be limited to one call per event.
  • Prerecorded calls by or on behalf of nonprofit organizations should be limited to one call per year.
  • Prerecorded healthcare calls to residential landlines should be limited in the same manner as that unconsented-to healthcare calls can be made to wireless numbers, as promulgated in the 2015 Omnibus Order.
  • The current numerical Limits on unconsented-to calls to cell phones should be retained.