Just a quick update here on the FCC and 1:1 consent rule during this holiday season.

The FCC is moving full steam ahead on a January 27, 2025 effective date as evidenced by the FAQs the Commission released on December 23, 2024.

Nothing groundbreaking in the FAQs for most TCPAWorld readers, but I appreciate this answer to one of the questions because it confirms what we have been telling clients for months now:

Does the new FCC requirement for one-to-one prior express written consent apply when a third party is added to on ongoing live telemarketing call?

… Indeed, the new one-to-one consent rule has no bearing on such calls. It only applies to calls made using an autodialer or prerecorded or artificial voice. However, if the third party seeks to reconnect with a consumer following this initial live call, the caller must obtain the necessary consumer consent if its future calls will be placed using an autodialed and/or prerecorded or artificial voice. (emphasis added).

So, while we all collectively turn our eyes to Atlanta for some sort of signal from the Eleventh Circuit, the FCC is ready to move forward. Smart companies are preparing to move forward as well.