The TSR changes regarding certain types of payment methods, which were announced in November of 2015, have now taken effect.  The  new FTC rules are aimed at stopping telemarketers from dipping directly into consumer bank accounts by using certain kinds of checks and “payment orders” that have been remotely created by the caller.

The FTC believes these two payment mechanisms make it easy for fraudulent telemarketers to debit bank accounts without the consumer's permission, and can make it difficult to reverse the transactions. The amendment also bars telemarketers from receiving payments through traditional “cash-to-cash” money transfers – provided by companies like MoneyGram, Western Union, and RIA.  "Cash reload" mechanisms are also now prohibited (think MoneyPack, vanilla Reload and Reloadit). 

Per the FTC, "scammers rely on cash transfers as a quick, anonymous, and irretrievable method to extract money from consumer victims – once it is picked up by the recipient, the money is gone." Those marketers who collect payments over the phone should review such rules carefully to ensure compliant payment methods are employed.  The FTC can fine companies up to $16,000 per individual violation; that ads up fast!