February 1, 2017
Student Loans
Letters to Congress
Petitioners argue that the Budget Rules are arbitrary and capricious and unsupported by either the language of the statute or the record. This is not the case. The record abundantly supports each feature of the Budget Rules. In fact, the Budget Rules are a textbook balancing act by the Federal Communications Commission of the competing goals of the statute: to allow some unconsented-to automated calls to collect federal debt, while protecting call recipients from invasive and costly calls consistent with the purposes of the Telephone Consumer Protection Act (TCPA).