For those needing answers also, I received this from Pauli.
Below is the FCC Declaratory Ruling and Order 15-72 Adopted June 18, 2015 which I sent you with regard to prior consent, and the fact that for four classes of calls/text it is not required. The opt-out provisions are specifically stated in conditions for exemption, but despite the fact that your account agreement gives the bank actual consent, the automated system messages themselves must provide the required to opt-out information regardless of whether or not the bank chooses to provide a written notice. This needs to be discussed with the vendor.
6) a financial institution must offer recipients within each message an easy means to opt out of
future such messages, voice calls that could be answered by a live person must include an
automated, interactive voice- and/or key press-activated opt-out mechanism that enables the call
recipient to make an opt-out request prior to terminating the call, voice calls that could be
answered by an answering machine or voice mail service must include a toll-free number that the
consumer can call to opt out of future calls, text messages must inform recipients of the ability to
opt out by replying â€œSTOP,â€ which will be the exclusive means by which consumers may opt out
of such messages; and,
7) a financial institution must honor opt-out requests immediately.