The FCC announced today that it is seeking public comment on petitions by the Direct Marketing Association and a coalition of mobile engagement providers directed at the commission’s latest TCPA regulations.  As we noted earlier this week, these petitions are part of the first wave of challenges to FCC regulations that went into effect on October 16, 2013 and could have significant detrimental impacts on telemarketers and lead generation companies.  The DMA petition seeks a forbearance from enforcement of certain disclosure requirements that might invalidate otherwise valid consents obtained previously.  And the coalition’s petition seeks a declaration that the new rules do not nullify those written express consents already provided by consumers before October 16, 2013. 

Public comments to the FCC on either petition are due by December 2, 2013, with reply comments due by December 17, 2013.  Thus, while the FCC is clearly moving forward on these issues, it seems unlikely that there will be a final ruling on these petitions before 2014.  Any company with a substantial interest in the outcome of these issues should consider filing a comment with the FCC before December 2, 2013.