AFSA Submits TCPA Comment to FCC October 22, 2018 AFSA and the Consumer Mortgage Coalition submitted comments to the Federal Communications Commission (FCC) on the Telephone Consumer Protection Act (TCPA). The FCC asked for comment on a recent 9th Circuit panel decision in Marks v. Crunch San Diego, LLC interpreting the definition of an “autodialer.” In Marks, the 9th Circuit decided that the definition of “autodialer” is broad and includes equipment that makes automatic calls from lists of recipients. The letter explained why the associations disagree with the court’s analysis in Marks. The FCC is currently drafting new proposed rules interpreting the TCPA, after the rules it wrote in 2015 were struck down (in part) by the DC Circuit Court. The proposed rules are expected to be released late this year or early next year.