So last Friday the FCC’s new TCPA revocation order went into effect.

While the nastiest parts of the ruling were stayed for one year thanks in large part to the major banks–thanks ABA/MBA and the rest of you!–a good portion of the rule did go into effect.

For those who are not on their revocation game and properly tracking requests the final approval order in a new TCPA class settlement arrives just in time to help you change your ways!

In Kamrava v. Cenlar 2025 WL 1116851 (C.D. Cal April 14, 2025) the court granted final approval to Cenlar’s settlement of a TCPA class involving servicing calls made after revocation of consent.

In many ways this was a throw back case as revocation classes have fallen by the wayside in recent years– leading to less focus on getting it right in some circles. Indeed, the case was filed way back in 2020 and is something of an oddity in today’s TCPAWorld landscape. However, the FCC’s new ruling supercharges risk here, which is why the settlement is so important.

The classes in Kamrava are as follows:

All persons within the United States who received an automated call to their cellular telephone, after revocation of consent, within the TCPA Class Period from defendant or a loan servicer on whose behalf Defendant was sub-servicing, its employees or its agents (the “TCPA Settlement Class”).
and 

All persons with addresses within the State of California who requested in writing that Defendant or the loan servicer on whose behalf Defendant was sub-servicing to stop contacting them and thereafter (i) received a letter asking them to sign and return a form confirming their cease-and-desist request or (ii) received at least one subsequent telephone call within the RFDCPA Sub-Class Period (the “RFDCPA Settlement Sub-Class”).

I was not involved in the case but I would guess what happened here is Cenlar was only temporarily stopping calls in response to an oral revocation request and then sending out a written letter which, if not returned within a certain timeframe, would result in calls beginning anew.

Thee claims arise between tension between TCPA and FDCPA/RFDCPA revocation rules. Under the debt collection statutes only written requests to stop calls must be honored. But under the TCPA any reasonable means of conveying a revocation is effective– so calls using regulated technology must stop immediately, even if manually launched calls may continue.

Its all part of a thicket of arcane TCPA requirements that can twist an ankle or skin a knee. And in this case Cenlar got snagged for nearly three quarters of a million dollars.