Artificial voice: do not confuse restriction with a blanket ban
The FCC’s February 2024 declaratory ruling places AI-generated voices within the TCPA’s artificial-or-prerecorded-voice framework. Calling purpose, consent and applicable exemptions remain material; the ruling does not mean every use of AI on the telephone is unlawful. (docs.fcc.gov)
Consent revocation: distinguish adoption from commencement
Manatt’s 5 October analysis describes an FCC order released on 1 October that revises informational-message revocation and permits designated revocation methods under specified conditions. It says the amendments take effect 30 days after Federal Register publication. This review did not establish the final effective date: obtain an updated legal determination before changing production opt-out handling. (manatt.com)
Healthcare: a badge is not a contractual evidence pack
HHS guidance says cloud providers handling electronic protected health information on behalf of a covered entity or business associate can themselves be business associates, including where the information is encrypted. Appropriate business associate agreements and risk analysis remain relevant; HHS does not certify or endorse specific cloud products. (hhs.gov)
Buyer action: Have counsel and security review the actual call flow, recordings, transcripts, subprocessors, retention, model-training terms and permitted system actions. This newsletter is procurement research, not legal clearance.