Skip to content

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?

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.

Wipfli's Financial Institutions Practice has served the banking industry for more than 85 years. Our seasoned professionals have banking experience, dedicate their time to clients throughout the United States, and provide regulatory compliance, information technology, risk management, strategic planning, board development, audit, and tax services. Visit, call 800.486.3454 or contact

First published on 09/20/2015

Filed under: 
Filed under operations as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics