IPA Submits Comment Letter To FCC On Robocall Proposed Rule

The Innovative Payments Association (IPA) recently submitted a comment letter to the Federal Communications Commission (FCC) in response to the agency’s proposed rule, Advanced Methods to Target and Eliminate Robocalls. The proposal would update requirements under the Telephone Consumer Protection Act (TCPA) and could have significant implications for how financial institutions and payments companies communicate with consumers.

In its comments, the IPA expressed support for the FCC’s efforts to combat illegal and unwanted robocalls, while emphasizing the importance of preserving consumers’ ability to receive critical, wanted communications from their financial institutions. The letter highlights several key considerations for policymakers as the Commission evaluates the proposed changes.

Key highlights:

• Protecting access to critical communications: The IPA cautioned that overly broad consent revocation requirements could unintentionally prevent consumers from receiving important messages, such as fraud alerts, low balance notifications, multi-factor authentication messages, and other account-related communications designed to protect consumers.
• Concerns with a universal or “revoke all” opt-out approach: The letter explains that allowing a single opt-out request to automatically stop all communications across unrelated business units or services may create confusion for consumers and operational challenges for financial institutions, without delivering clear consumer benefits.
• Operational and compliance challenges: The IPA outlined the complexity financial institutions—particularly smaller institutions—would face in implementing systems capable of instantly halting all communications across multiple platforms, vendors, and business lines.
• Need for regulatory clarity and cost-benefit analysis: The association urged the FCC to conduct a thorough cost-benefit analysis of the proposed consent revocation provisions, including their impact on small institutions, and to consider refinements that would provide greater operational certainty while maintaining consumer protections.

The IPA reiterated its willingness to engage in continued dialogue with the FCC and other stakeholders to ensure that efforts to reduce illegal robocalls do not unintentionally undermine consumer protection, financial security, or effective communication.

Download Comment Letter