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Monthly TCPA Digest — June 2022

We are pleased to present our latest Monthly TCPA Digest, providing insights and news related to the Telephone Consumer Protection Act (TCPA). In this issue’s Regulatory Update, we report on a Public Notice issued by the FCC’s Wireline Competition Bureau directed at non-facilities-based "small providers" — or those voice service providers with 100,000 or fewer voice access lines. The Public Notice reminds this category of providers they must implement STIR/SHAKEN caller ID authentication technology on the Internet Protocol portion of their networks by June 30, 2022. Facilities-based small providers suspected of originating illegal robocalls are also subject to the new deadline. Last year, the FCC moved up the compliance deadline for small, non-facilities-based providers based on evidence that they were originating large numbers of illegal robocalls. Small providers subject to the deadline must also update their certifications and associated filings in the Robocall Mitigation Database within 10 business days of implementing STIR/SHAKEN.

In our Litigation Update, we cover the Oklahoma Telephone Solicitation Act of 2022, a so-called “mini-TCPA” law enacted in the wake of the US Supreme Court’s decision in Facebook v. Duguid, which significantly limited the application of the TCPA to live calls and text messages. Oklahoma’s law will prohibit the use of an automated system to make a commercial telephonic sales call without the recipient’s prior express written consent when it takes effect on November 1, 2022. Florida has a similar statute, and legislation is also pending in Georgia and Washington.

If you have suggestions for topics you’d like us to feature in this newsletter, or any questions about the content in this issue, please feel free to reach out to an attorney on Mintz’s TCPA and Consumer Calling Practice team.

In This Edition 

Part I – TCPA Regulatory Update

FCC Reminds Small Providers of STIR/SHAKEN Deadline

Part II – TCPA Litigation Update

Oklahoma: The Latest State to Enact a “Mini-TCPA”


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Russell H. Fox is a wireless communications attorney at Mintz. He guides clients through federal legislative, regulatory, and transactional matters. Russell also participates in FCC proceedings, negotiates spectrum agreements, and represents clients in spectrum auctions.
Jonathan Garvin is an attorney at Mintz who focuses on legal challenges facing companies in the communications and media industries. He advises clients on transactional, regulatory, and compliance issues before the FCC involving wireless, broadband, broadcast, and cable matters.

Matthew Novian