Last week the FCC released a forfeiture order against Travel Club and several other related parties imposing a fine of $2,960,000. This fine was based on 185 unsolicited robocalls in violation of the TCPA (185 violations x $16,000 per violation).

Normally, you would except to see some sort of settlement agreement where the businesses are required to pay less than the maximum fine amount. This was not the case here, as none of the defendants timely filed a response to the FCC’s Notice of Apparent Liability that was issued back in 2011.
 
This is yet another reminder of why excellent compliance practices are so important. A single error in your compliance practices can easily lead to hundreds, if not thousands, of separate violations in a remarkably short period of time.