As previously covered in other TCPA blog posts, the FCC
maintains a range of TCPA rules addressing certain key elements of
telemarketing and even non-telemarketing call activities that can
implicate routine interactions between companies and their
customers or prospective customers. The proper scope and
interpretation of some of these rules continue to be the subject of
newly filed petitions for clarification, declaratory ruling or even
requests for outright waiver of certain FCC rules. We highlight
here several of the more recent additions to the FCC's already
large compliment of pending TCPA petitions.
ACA International filed a petition for rulemaking in late
January seeking FCC rule updates or clarifications to dispel the
possibility that all predictive dialing technology, regardless of
its actual use and configuration, could be deemed to be an
automatic telephone dialing system (ATDS). ACA is a trade
organization of debt collection companies. (See ACA
