Articles

These articles draw on extensive research in order to produce incisive, relevant legal analysis of the telemarketing industry.


January 2012

Automated Reminder Messaging - A Legal Primer For Agency Directors

By: William Raney

If you are considering the use of an automated reminder messaging (“ARM”) in your agency, this paper can help by providing legal background regarding ARM which you can use with your counsel to conduct a legally compliant campaign.

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January 2012

How a Single State Can Make “National” Law

By: William Raney

A business that seeks to be completely compliant should look to national rules, such as the Telemarketing Sales Rule, but also “national” state laws - laws, though passed in a single state, are of such importance that calls to the entire nation are affected.

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January 2012

FTC Gives Guidance with Regard to Company-Specific DNC Lists - in the Form of a Lawsuit!

By: William Raney

What, exactly, constitutes a company-specific “do-not-call” request? While the FTC and FCC previously stated that any form of a request is valid, neither agency has issued much guidance to answer the question. The guidance has come in the form of a lawsuit, filed against the Americall Group, for “interfer[ing] with entity-specific do-not-call requests.”

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January 2012

SEC Adopts New Regulations for Telephone Solicitations

By: William Raney

The SEC has adopted new rules with regard to telemarketing activity.

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December 2011

Jurisdictional Issues in TCPA Private Causes of Action

By: Kristen Marshall

As the number of TCPA-related lawsuits filed by private plaintiffs increases, debate has turned to which courts, state or federal, have jurisdiction to hear these lawsuits. Until the Supreme Court issues its decision regarding federal question jurisdiction pursuant to the TCPA, the debate will continue and many seeking their claims to be heard in federal court will be forced to rely on diversity jurisdiction.

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October 2011

Strict Liability and the TCPA

By: Kristen Marshall

The FCC has issued a request for comments about the circumstances in which a person or entity is liable for telemarketing violations committed by third parties acting on the person’s or entity’s behalf. This article examines the issues involved in a third party calling “on behalf of” a person or entity.

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August 2011

Which Curfew Statute Applies When a Consumer Uses a Mobile Telephone Number?

By: William Raney

Regarding mobile phones, the FCC will likely apply the current logic used for landlines. That is to say, if a consumer at her sole discretion moved but kept the same mobile number and old area code, and did not notify the caller of the new address, the caller could rely on the old area code to determine applicable curfews (assuming compliance with other rules including but not limited to the TCPA ATDS rules.)

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June 2011

The Test of Being a Charity

By: Errol Copilevitz

According to the Internal Revenue Code and Regulations, charities must be “publicly supported.” This article reviews the criteria for that requirement.

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September 2010

TSR Amendments Target Debt Relief Services

By: Kristen Marshall

With its recent revisions to the Telemarketing Sales Rule (TSR), the Federal Trade Commission has added yet another group to the list of those affected by its rules.

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August 2010

What Rules Apply When You Accept Credit Cards for Payment Over the Telephone?

By: William Raney

In a field of law with many regulators at multiple levels imposing sometimes restrictive and sometimes redundant rules, the restrictions applicable to telemarketers when accepting a credit card payment over the telephone are surprisingly few and easy to implement for legitimate companies.

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