What wholesalers must know about TCPA, one-to-one consent, and A2P 10DLC in 2026 — fines, opt-outs, and how to stay compliant. Read the guide.
This article is informational and not legal advice. Consult counsel before launching any outreach program. Can you legally cold text motivated sellers in 2026? Short answer: not from purchased lists, and not without prior express written consent for marketing content. A2P 10DLC carriers block 100% of unregistered traffic since Feb 1, 2025 — throttling is over, blocking is absolute. TCPA basics for wholesalers $500 per violation, $1,500 if willful, no aggregate cap. One verdict reached $925M for 1.8 million violating calls. Class actions rose roughly 95% year-over-year in mid-2025.
The one-to-one consent rule — what actually happened The FCC postponed enforcement to Jan 26, 2026. On the same day, the 11th Circuit vacated the rule in IMC v. FCC. Treat the underlying consent standard as still operative even though the specific rule is gone. A2P 10DLC registration explained Register your brand and campaigns with The Campaign Registry. Unregistered traffic is blocked at the carrier level. Fines reach $10,000. Opt-out / revocation rules Since April 2025, consumers may revoke consent through any reasonable method. Senders must honor opt-outs within 10 business days.
State mini-TCPAs (Texas SB 140, Virginia SB 1339) Texas SB 140 (effective Sept 1, 2025) treats promotional texts as telephone solicitation with $500-$5,000 per-violation exposure under DTPA and treble damages for willful violations. How a compliant appointment service handles this for you Registered 10DLC, opt-in language, suppression lists, consent records, and a documented complaint workflow — all maintained as a standing program, not a one-time setup.