Each of the areas addressed by the notice could affect the bulk sms ireland compliance programs of callers and texters, and the notice thus represents an opportunity to inform the fcc of practical consequences of its proposals before it acts to adopt new rules.Revocation of consent in “any reasonable way”in its declaratory ruling, the fcc stated that consumers who had provided prior express consent to receive autodialed or pre-recorded voice calls are free to revoke that consent through any reasonable means of notification to the calling or texting party. The notice proposes to formally adopt a rule incorporating that flexibility and prohibiting calling or texting parties from designating any exclusive means to revoke consent.

The proposed rule states that reasonable revocation methods “typically” include text messages, voicemail or email to any phone number or email address where the consumer “can reasonably expect” to reach the caller. The notice calls out the use of “stop” as a widely recognized means of revoking consent and proposes that the fcc employ a presumption that such a message, if sent, it is to be treated as a revocation of consent message. If text initiators do not allow or enable a reply to text function, then the fcc proposes that that entity be required to provide clear and conspicuous disclosure on each text as to how to revoke consent.