Ringless Voicemail (RVM)
A technology that deposits a prerecorded voicemail on a consumer's phone without causing the device to ring — legally treated as a call under TCPA by most courts.
Full Definition
Ringless voicemail (RVM) delivers a prerecorded audio message directly into a voicemail inbox via a server-to-server connection, bypassing the ringing of the consumer's handset. Vendors have historically argued RVM is not a "call" under TCPA, but every federal court to consider the question since 2017 (including the Eastern District of Michigan in Saunders v. Dyck O'Neal and the 11th Circuit) has held RVM is a call subject to TCPA. The FCC affirmed this view in a 2022 declaratory ruling. Practically: RVM requires the same prior express written consent as any other autodialed or prerecorded call. It remains popular because drop rates are cheap and pickup on callback is high, but compliance teams must treat RVM identically to prerecorded-message campaigns.
Example
A final expense agency drops 5,000 RVMs to aged leads with documented PEWC. Callback rate is 6%. The agency logs each RVM drop with the lead's TrustedForm certificate for audit.
Common Misconceptions
Ringless voicemail is widely marketed as "TCPA-exempt." It is not. Federal courts and the FCC treat RVM as a call requiring PEWC for marketing purposes.
Related Terms
- TCPA (Telephone Consumer Protection Act) — U.S. federal law restricting telemarketing calls, autodialed calls, prerecorded messages, and text messages without prior express written consent.
- Prior Express Written Consent (PEWC) — A TCPA-defined standard of consent requiring a signed, written agreement that clearly authorizes autodialed or prerecorded marketing calls and texts.
- Dialer (Predictive / Power / Manual) — Outbound calling software that accelerates agent dial volume — operating in predictive, power, progressive, or manual modes with very different TCPA risk profiles.