News & Analysis as of

Financial Services Industry Prior Express Consent

Womble Bond Dickinson

Litigation Regarding Refer-a-Friend Programs Under Long-Standing Washington Commercial Texting Prohibition on the Rise

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Washington state’s Consumer Electronic Mail Act (“CEMA”), a statute enacted back in 2003 prohibits companies conducting business in Washington state from sending or providing “substantial assistance or support” in the...more

McGlinchey Stafford

Lack of Actual Knowledge and Prior Express Consent Defeats FDCPA and TCPA Claims

McGlinchey Stafford on

The U.S. District Court for the District of Nevada granted a defendant’s motion for summary judgment in a case arising under the Fair Debt Collection Practices Act (FDCPA) and the Telephone Consumer Protection Act (TCPA). It...more

Troutman Pepper Locke

Nevada Federal Court Grants Summary Judgment in Debt Collector’s Favor in FDCPA and TCPA Case Alleging Attorney Representation and...

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On September 9, the U.S. District Court for the District of Nevada granted summary judgment in favor of a debt collector in a case involving alleged violations of the Fair Debt Collection Practices Act (FDCPA) and the...more

Troutman Pepper Locke

Kentucky Introduces Legislation Requiring CRAs to Obtain Express Consumer Consent Prior to Furnishing a Consumer Report or Credit...

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On February 16, Kentucky state representative Steve Bratcher (R) introduced House Bill (HB) 578. The bill seeks to create a new section of the Kentucky Consumer Protection Act that would restrict how consumer reporting...more

Venable LLP

Lead Generation: An Excerpt from the Advertising Law Tool Kit

Venable LLP on

In the evolving world of lead generation and performance-based customer acquisition, the quest for profits can lead to big legal risks, some of them too large for advertisers that buy leads through third parties. Advertisers...more

Ballard Spahr LLP

New FCC rule on TCPA consent for advertising and telemarketing calls and texts will significantly impact callers who obtain...

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By a vote of 4-1, the Federal Communication Commission (FCC) adopted a new rule amending its regulations implementing the Telephone Consumer Protection Act (TCPA) to close what it refers to as the “lead generator loophole.”  ...more

Troutman Pepper Locke

Wisconsin Federal Court Finds that DNC Provision Extends to Text Messages

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On September 21, the Eastern District of Wisconsin denied a motion to partially dismiss a class action complaint alleging violations of the Telephone Consumer Protection Act (TCPA), holding that the Do Not Call provision of...more

Holland & Knight LLP

Update on Hunstein Decision: Eleventh Circuit Vacates Original Panel Decision

Holland & Knight LLP on

The U.S. Court of Appeals for the Eleventh Circuit issued its initial opinion on Hunstein v. Preferred Collection and Management Services, Inc., No. 8:19-cv-00983-TPB-TGW on April 21, 2021. As previously discussed in a...more

Ballard Spahr LLP

Ninth Circuit rules TCPA prior express consent for autodialed calls must come from current subscriber, not intended recipient

Ballard Spahr LLP on

The U.S. Court of Appeals for the Ninth Circuit has joined the Seventh and Eleventh Circuits in ruling that the “prior express consent” required by the Telephone Consumer Protection Act (TCPA) for autodialed calls to cellular...more

Burr & Forman

California District Court Holds Revocation of Consent Sent to Corporate Headquarters Does Not Support TCPA Claim

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Vanessa Wright v. USAA Savings Bank, No. 2:19-cv-00591 WBS CKD, 2020 WL 2615441 (E.D. Cal. May 22, 2020) - Plaintiff, who had a credit card account with Defendant for approximately 18 years, retained counsel to address...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending January 31, 2020

Carlton Fields on

Real Property Update - HOA / Contracts: Trial court erred by entering a post-judgment enforcement order requiring the association to assign its riparian rights to plaintiff pursuant to an enforceable settlement agreement,...more

Womble Bond Dickinson

TCPA 101: Court Ruling Reminds Us of the Fundamentals for Debt Collection Calls

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In the realm of TCPA litigation, consent and revocation are bedrock issues that TCPA practitioners encounter on a daily basis. Amidst the often times complicated and nuanced legal issues surrounding the TCPA, a court in the...more

Rumberger | Kirk

Significant FCC Ruling Distinguishes Online Fax Services Not in Violation of TCPA

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In a welcome win to defendants fighting TCPA fax class actions, the Consumer and Governmental Affairs Bureau of the Federal Communications Commission (the Bureau) issued a declaratory ruling finding that a facsimile sent to...more

Carlton Fields

Financial Services Update: Week Ending November 1, 2019

Carlton Fields on

Financial Services Update - FCCPA and FDCPA: The plaintiff did not demonstrate a genuine issue of material fact that medical providers and their attorney violated the FCCPA and FDCPA by conditioning medical services on a...more

Burr & Forman

Middle District of Florida Holds Aspect Dialer is Not an ATDS under the TCPA

Burr & Forman on

In addressing cross motions for summary judgment in BONNIE BROWN & JAMES BROWN, Plaintiffs, v. OCWEN LOAN SERVICING LLC, Defendant., 8:18-CV-136-T-60AEP, 2019 WL 4221718 (M.D. Fla. Sept. 5, 2019) (“Browns v. Ocwen”) on...more

Carlton Fields

Real Property & Financial Services Update: Week Ending August 16, 2019

Carlton Fields on

Real Property Update - Construction / Statute of Repose: the installation of an attic ladder is an improvement to real property; thus, the ten-year statute of repose of section 95.11(3)(c) applies - Harrell v. The Ryland...more

Ballard Spahr LLP

Eighth Circuit Rules Against Telemarketing Company on TCPA Claim, Yet Declares $1.6 Billion in Statutory Damages Unconstitutional

Ballard Spahr LLP on

The U.S. Court of Appeals for the Eighth Circuit found that unwanted, prerecorded phone messages to consumers, even without any other alleged harm, met the injury-in-fact requirement for Article III standing to bring a...more

Ballard Spahr LLP

Ninth Circuit decision on TCPA autodialer definition settles: what does it mean?

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In September 2018, in Marks v. San Diego Crunch, a unanimous Ninth Circuit three-judge panel held that the TCPA’s definition of an automatic dialing system (ATDS) includes telephone equipment that can automatically dial phone...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending November 16, 2018

Carlton Fields on

Real Property Update - Derivative v. Direct Action / Standing: individual member of LLC not entitled to sue title company for breach of fiduciary duty because right to sue belonged to LLC, where LLC suffered the direct...more

Burr & Forman

District Court of Minnesota Finds Calls to a Reassigned Number Did Not Violate the TCPA

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In Roark v. Credit One Bank, N.A., No. 16-173 (PAM/ECW), 2018 WL 5921652 (D. Minn. Nov. 13, 2018), the District Court of Minnesota found that calls to a reassigned phone number did not violate the TCPA because the caller’s...more

Womble Bond Dickinson

It’s all So Clear Now: When Asked a Second Time Court Makes Sure to Clarify that the TCPA Still Applies to Debt Collection Calls

Womble Bond Dickinson on

There’s nothing wrong with pushing your luck, in theory. But once in a while luck pushes back. A few weeks back Ocwen obtained an almost-great ruling in Wilfredo Gonzalez v. Ocwen Loan Servicing, Case No:...more

Womble Bond Dickinson

Either “Called Party” Will Do: Consent from Subscriber Husband Defeats Wife’s TCPA Claim Even Though She Was the Customary User of...

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Its a factual scenario that arises far more than it should. A customer provides a cell phone number to a business, consenting to receive phone calls in the process. Phone calls are placed to that customer at that number. But...more

Smith Debnam Narron Drake Saintsing & Myers,...

District Court Holds Revocation of Consent Ineffective in the Face of Contractual Consent

Relying upon basic principles of contract law, an Alabama district court has held that there are limitations to revocation of prior express consent. In Few v. Receivables Performance Management, 2018 U.S. Dist. LEXIS 134324...more

Burr & Forman

District Court of Connecticut Follows Reyes Decision

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In Harris v. Navient Solutions, LLC, No. 3:15-cv-564 (RNC), 2018 WL 3748155 (D. Conn. Aug. 7, 2018), the United States District Court for the District of Connecticut followed the Second Circuit’s decision in Reyes v. Lincoln...more

Womble Bond Dickinson

Contracts 101: Court Rules Contractual TCPA Consent Is Irrevocable Even if the Contract Doesn’t Specifically Say So

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Well it has been a while since we’ve had anything to report regarding case law developing around “Good Reyes”–Reyes v. Lincoln Auto. Fin. Servs., 861 F.3d 51, 56 (2d Cir. 2017), as amended (Aug. 21, 2017). Indeed, with all...more

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