Following 180 days of membership into R . E . A . C . H ., no MLS shall use prerecorded or artificial voice technology to make initial contact with a consumer , or authorize any third party to do so , or sell any lead to any MLP where an initial contact with a consumer was made using any prerecorded or artificial voice technology .
No MLP or GSP shall use any prerecorded or artificial voice technology to contact any purchased lead for marketing purposes . Nothing in this provision shall prevent the use of such technology to contact a consumer that has provided consent directly to a GSP on a first-party website , provided that a member GSP will not use such technology as an initial contact .
Prerecorded or artificial voice technology include prerecorded and artificial voicemails , outbound IVR , ringless voicemail , and any other contact method where the consumer ’ s first interaction over the telephone is with a synthesized human voice .
Nothing in this provision shall prevent the use of such technology — assuming a valid consent event has occurred and not been withdrawn — after a consumer has been successfully contacted by the caller .
All prerecorded voice calls shall comply with every element of the content requirements of applicable TCPA , TSR and regulatory provisions .
As discussed at contact . io , the R . E . A . C . H . standards do permit leads to be sold but only where a consumer has accepted an extremely clear website disclosure :
Upcoming Noteworthy Dates
Where you can find Troutman Amin , LLP in the next few months !
October 14 , 2023
Irvine Global Village Festival ( Troutman Amin , LLP in attendance )
October 16-17 , 2023
Somos Telecom Symposium-Charlotte , NC ( Troutman Amin , LLP in attendance )
October 17 , 2023
Affy Awards — Hollywood , CA ( Troutman Amin , LLP in attendance )
October 26 – 29 , 2023
NHRA Nevada Nationals — Las Vegas , NV ( Troutman Amin , LLP in attendance )
November 7-8 , 2023
Cardcon — Nashville , TN ( Troutman Amin , LLP in attendance )
November 8-10 , 2023
ACA Int ’ l Fall Forum — Chicago , Ill ( Troutman Amin , LLP in attendance )
November 10-12 , 2023
Auto Club NHRA Finals — Pomona , CA ( Troutman Amin , LLP in attendance )
It is hoped the FCC will adopt this proposal instead of the Public Knowledge proposal preventing the sale of data leads consistent with the FTC ’ s new position as discussed in our July 27 blog post , which can be found on our website , TCPAWorld . com .
As I told everyone at contact . io — R . E . A . C . H . is still fighting hard for everybody but we need help if we are going to win this thing . Connect with us today via our website or email me at jenniffer @ TroutmanAmin . com .
December 4-6 , 2023
TCPA Summit — St . Petersburg , FL ( Troutman Amin , LLP in attendance )
December 17 , 2023
Troutman Amin , LLP Christmas party in Bourbon Trail Kentucky
January 7-9 , 2024
Lead Generation World — Florida ( Troutman Amin , LLP in attendance )