So just an absolutely massive settlement to chat through today, and one everybody saw coming.

TCPAWorld.com readers will, of course, recall the story of Citibank being crushed with a certification decision back in 2022.

At the time I reminded everyone that TCPA “is the single biggest risk facing most organizations.”

I have to say, however, given the massive exposure Citibank was facing it got out relatively cheap when it agreed to pay $29.5MM to the class. That’s how much they have agreed to pay to resolve the case.

That is just a massive sum to pay for TCPA violations. Not good.

The class definition is:

All persons and entities throughout the United States (1) to whom Citibank, N.A. placed a call in connection with a past-due credit card account, (2) directed to a number assigned to a cellular telephone service, but not assigned to a current or former Citibank, N.A. customer or authorized user, (3) via its Aspect dialer and with an artificial or prerecorded voice, (4) from August 15, 2014 through July 31, 2024.

Unclear how many people were in this class but it IS clear that the cause of this TCPA catastrophe was calls to wrong numbers.

While not all calls to wrong numbers can be avoided, calls to reassigned numbers can be using the FCC’s reassigned numbers database!

In fact it was this EXACT FACTUAL SCENARIO– collection calls by a major bank (WF) that lead to the creation of the FCC’s RND database to begin with.

The fact that so many banks (and other) institutions are not using the RND is absolutely flat nuts to me.

Regardless Citibank is writing a large check and will soon be absolved of TCPA wrongdoing it seems (final approval has not yet been granted but this settlement seems appropriate to me) but YOUR company really should be keeping an eye on wrong number calling risk– even if you’re in the relatively safe(r) servicing/collection space.

Case is: Christine Head v. Citibank, N.A., Case No. 3:18-cv-08189-ROS (D. Arizona)

BTW the Plaintiff’s lawyer in Head was Mike Greenwald. You may want to listen to what he has to say on the subject: