Yes, the TCPA rules would apply since you intend to sell a service, and the word "services" is included in the definition of telephone solicitation. Even though no immediate payment is required, in order to use the service, a fee is involved.
Telemarketing to Boost Overdraft Protection Customer Participation
If we use a telephone campaign to increase our overdraft protection opt-in customer participation, would the Telephone Consumer Protection Act (TCPA) apply? We know a current business relationship no longer qualifies as consent for contact, but we also need to honor do-not-call list restrictions. Since we would be soliciting customers to sign up, but with no purchase or monetary investment required, does this even qualify as a telemarketing call?
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First published on 09/20/2015