Huge news out of the FCC folks—the Delete, Delete, Delete docket has come home and the chickens are roosting (and laying tasty looking eggs!)
Big changes may be coming to the TCPA—including a wholesale destruction of the internal DNC paradigm, the end of the tortuous abandon call rules, and a rollback of the INSANE revocation rules that were set to take place next April.
But.. none of this has happened yet. And it will be in YOUR hands to help the Commission do the right thing.
You can fully expect R.E.A.C.H. to take a leading role in building out response to the Commission but YOU should also get informed and get involved.
Without further adieu, here’s some key takeaways of what’s under CONSIDERATION (none of this is final folks—just proposals that need to be commented on):
As part of modernizing anti-robocall protections the FCC proposes simplifying or eliminating outdated requirements and plans to dismiss older TCPA petitions and applications for review:
Call Abandonment Rules
The FCC is proposing to eliminate its call abandonment rules which currently prohibit telemarketers from disconnecting unanswered calls before 15 seconds or four rings and limit abandoned calls to no more than 3% of telemarketing calls.
- These rules were originally adopted under the DNC Implementation Act (“DNC Act”) to align FCC rules with the FTC’s TSR which still contains similar provisions
- The FCC suggests elimination could reduce compliance burdens on callers (e.g, tracking and documenting call data) and seeks comment on:
- Whether the DNC Act requires the FCC to keep these rules?
- Whether differences in FCC v. FTC jurisdiction argue for retaining or deleting them?
- Whether having only FTC rules (applicable to certain callers) would cause confusion for businesses and consumers about call abandonment standards?
Company-Specific DNC Rules
The FCC proposes to delete its company specific DNC rules which currently require callers to record and honor a consumer’s direct DNC request.
- In 2003 the FCC adopted these rules alongside the National DNC Registry with the company specific rules intended to supplement the national list by letting consumers block calls from particular businesses
- Over time the National DNC Registry has become the primary protection, covering autodialed, prerecorded, and live solicitation calls
- The FCC now believes that general anti-robocall rules (e.g consent revocation and National DNC Registry compliance) may make company specific DNC rules unnecessary
- Considerations for Comment:
- Is the National DNC Registry alone sufficient to protect consumers or do consumers still need company specific opt-outs?
- Should certain requirements be retained such as automated opt out mechanisms for prerecorded or telemarketing calls?
- Do company specific rules still provide unique consumer benefits not covered by other rules?
- What is the compliance burden on callers? Could the rules be streamlined instead of eliminated?
- How should the FCC weigh its duty under the DNC Act to maximize consistency with FTC rules while still modernizing?
- Could differing FCC and FTC rules cause confusion for callers and consumers?
Artificial and Pre-Recorded Voice Caller Identification Rules
The FCC proposes to modernize its caller identification rule for artificial and pre-recorded voice calls.
- Under the current rule callers must provide a callback number that is not a 900 number (or any other number for which charges exceed local or long distance transmission charges) and for telemarketing/residential calls the number must accept DNC requests during business hours
- FCC proposes to streamline the rule to just require that callers identify themselves with a valid telephone number so consumers can recognize who is calling
- Traditional “local v. long distance” charges are largely obsolete and the rule should reflect today’s telecommunications marketplace
- FCC seeks Comment on:
- Does the change better fit modern calling practices?
- What effect would this update have if the FCC also eliminates company specific DNC rules?
Consent Revocation Rules
The FCC is considering two key rules around consumer revocation of consent under the TCPA.
- Current rule requires that if a consumer opts out of one type of call/text, it applies to all calls/texts from that caller, even on unrelated matters. Implementation of this requirement has been delayed until April 11, 2026
- FCC proposes deleting or modifying this rule because it may prevent consumers from receiving wanted calls (e.g. from healthcare providers, pharmacies, banks, or businesses with multiple lines of service)
- FCC seeks comment on whether the all or nothing approach is too burdensome for callers or whether requiring separate revocations for different business units location, practitioner, or other sub-division of a caller would be more workable?
- The FCC also proposes revising §64.1200(a)(10), which currently requires callers to honor revocations made through any “reasonable means”
- Some commenters want callers to be able to designate the exclusive method for revoking consent
- The FCC seeks input on whether less restrictive alternatives exist, what methods should be required or prohibited, how to ensure disclosures are clear, and whether complex revocation procedures could deter consumers
- They ask whether such amendments would give more certainty and efficiency for both consumers and callers
Fraud Alert Call Rules
The FCC is considering eliminating the current fraud alert call rule that limits financial institutions to contacting only the telephone number provided by the consumer when making fraud alert or similar calls under the TCPA exception.
- This restriction may unduly limit financial institutions from delivering critical fraud related messages to consumers about their accounts
- FCC asks:
- Would broadening the rule risk misdirected calls or improper disclosure of financial information?
- Does the ability of institutions to obtain prior express consent mitigate these risks?
- Should the FCC align this proposal with other federal/state laws or industry best practices?
- Would broader flexibility improve fraud prevention and consumer protection?
- How should the tradeoff between fraud risk reduction and potential misdirected calls be evaluated?
Call Blocking Rules
The FCC proposes to eliminate its call blocking rules that permit voice service providers to block calls from Numbers on a do-not-originate (DNO) list and numbers that are invalid, unallocated, or unused.
- Per the FCC these provisions have become unnecessary because the FCC has since adopted rules that require providers to block such calls making the earlier permissive rules redundant
STIR/SHAKEN Framework, Rich Call Data, Presenting Caller Name:
- Limitations of CNAM Databases – STIR/SHAKEN has reduced spoofing, legacy CNAM databases remain the main source of caller name information but are widely considered unreliable, error-prone, and subject to manipulation
- INSTEAD RCD builds on the STIR/SHAKEN framework using encryption to transmit additional caller identity information over IP networks.
- Information can include name, photo, logo, email, location, title, and call purpose (within data limits)
- Unlike CNAM, RCD does not query a third-party database. Instead, the originating provider transmits vetted identity information, which the terminating provider verifies
- RCD is governed by ATIS and IETF standards. ATIS requires originating providers to vet identity information, while attestation levels under STIR/SHAKEN still apply only to the provider’s knowledge of its direct customer and their right to use the number
- In 2023 FCC sought comment on requiring terminating providers to provide accurate caller name information when transmitting A-level authenticated calls and asked about CNAM’s role
- Commenters broadly agreed that CNAM should not be used because of its inaccuracy
- In February 2025, the FCC encouraged industry to develop RCD and branded calling solutions and signaled that it may consider mandating their use in the future
- In May 2025 TransUnion filed about a validation solution that lets terminating providers present validated business information (e.g. name, logo, call reason) with calls
- The solution aims to reduce both fraudulent calls that go unidentified, and awful calls incorrectly flagged as spam/fraud
- TransUnion emphasized the need for accurate branding information, though it did not specify if its solution uses Rich Call Data (RCD).
- Instead it noted reliance on a combination of industry standards (IETF, ATIS, SIP Forum)
- Hiya, Twilio, CTIA, TNS, and Numeracle also advertise branded calling solutions with similar capabilities
- It remains unclear how much these offerings are proprietary versus based on RCD but all appear to provide functions comparable to RCD
The FCC states STIR/SHAKEN reduces spoofing but doesn’t tell consumers who is callin and an A-level attestation alone can be misleading. Requiring verified caller name and identity information would give consumers clearer, more reliable information, increase trust, and improve provider analytics by reducing mislabeling:
Defining Caller Identity Information
FCC proposes to define “caller identity information” consistent with “caller identification information” in the FCC rules, but exclude the originating telephone number and billing number information.
- Terms like “Caller ID” traditionally referred to the originating phone number and “Caller ID with Name” included the number plus a caller name from a CNAM database
- The Truth in Caller ID Act and FCC rules define “caller identification information” to include the originating number and “other information regarding the origination of the call.”
- Rules specify certain enumerated items plus “[o]ther information regarding the source or apparent source of a telephone call.”
- Any service/device used to provide such information is a caller identification service.
- “Caller ID authentication” often refers narrowly to authenticating the originating number only
- To avoid duplication with existing number-authentication rules, the FCC proposes to use “caller identity information” to mean the caller’s name, location, and “other information regarding the source or apparent source of a telephone call,” – excluding the originating number and billing information – and seeks comment on this approach
Requiring Transmission of Caller Identity Information to Consumers when A-Level Attestations are Indicated
FCC propposes terminating providers to transmit verified caller ID to consumer handsets whenever they transmit an indication that a call received an A-level attestation.
- This requirement would apply only if a provider chooses to display an A-level attestation; it would not mandate transmitting attestation itself or new caller ID information
- Presenting an A-level attestation indicator with only the originating number provides little benefit, since consumers may not understand it and may mistakenly assume the call is not a scam.
- Verified caller ID benefits both consumers and legitimate callers, especially businesses, by improving trust, answer rates, and engagement.
- FCC believes combining verified caller ID with attestation provides significant benefit
- Does showing attestation without identity information create opportunities for fraud? Would providers stop transmitting attestation indicators if this rule is adopted? Would that undermine STIR/SHAKEN?
- FCC proposes requiring at least a verified caller name (personal or business), since not all callers have logos or branding.
- FCC seeks Comment on whether exceptions are needed for callers with a legitimate need for privacy (domestic violence shelters, *67 blocking, privacy settings). ATIS RCD standard already restricts transmission when privacy is requested
- Consumers use various devices (wireline, IP phones, mobile) — modern smartphones can display logos and text, and most operating systems support verified caller ID
- FCC seeks comment on differences across manufacturers and operating systems, how to ensure consistency, and whether IP or wireline phones can at least display verified caller name
- FCC also seeks comment on impacts for people with disabilities using assistive devices (braille readers, TTY, built-in phone accessibility tools). Considers how digital conversion or third-party devices affect transmission of caller ID.
- FCC seeks Comment on how caller ID and attestation are transmitted when TRS providers connect calls
- Is the information presented for the caller or the TRS center?
- Does this vary by type of TRS (TTY, STS, VRS, IP Relay, IP CTS)?
- How do these differences affect consumer trust and likelihood of answering?
- What steps should be taken to ensure end-to-end transmission of caller identity for TRS calls?
Requiring Originating Providers to Verify that Transmitted Caller Identity Information is Accurate
The FCC proposes to require originating providers that transmit caller ID to take reasonable measures to verify accuracy.
- Caller ID is only valuable if accurate; inaccurate information may cause consumers to trust unlawful callers and further erode trust in the network
- FCC proposes the following questions for Comment:
- What measures should be viewed as “reasonable”?
- Should rules prescribe specific measures, standards, or criteria for reasonableness?
- Should providers be required to collect and verify specific information? If so, what information and how should it be verified?
- Should providers have flexibility in verification, subject to minimum standards or guidelines?
- Should requirements differ if the originating provider is a reseller or uses a third-party branded calling solution?
- Could contractual requirements (customers must provide only accurate/authorized names, logos, etc) suffice?
- Should FCC define what constitutes “accurate” information?
- Differentiation among callers-
- Should requirements vary for government, non-profit, business, or individual callers?
- Should differentiation be based on call volume (high v. low volume) and if so what threshold?
- For business callers, what steps should providers take to ensure use of accurate and authorized business names, brands, or logos?
- For franchisees or individual locations, should different rules apply?
- For individual callers, should verification be tied to government-issued identification or alternative approaches?
- Special situations:
- Should individuals be allowed to transmit nicknames or non-legal names in some contexts?
- How should multi-line accounts (family plans) be handled, especially where each line has a different name?
- Should safeguards apply to minors’ names on family plans (exception for under 18 or use of generic labels)?
- How would rules apply to sensitive calls, such as to crisis hotlines (988, domestic violence hotlines)?
- Industry standards and practices-
- ATIS RCD standard includes provisions on vetting caller ID
- CTIA has issued branded calling best practices
- FCC seeks comment on whether such industry standards are sufficient, appropriate, enforceable and whether they mitigate the need for new requirements
Securely Transmitting Caller Identity Information
The FCC seeks comment on requirements to ensure caller identity information is securely transmitted from the originating to the terminating provider, including whether to require the use of RCD standards
- Per the FCC if identity information is changed or tampered with in transit, verification by the originating provider will not benefit consumers or callers.
- Is secure transmission necessary to prevent alteration by bad actors?
- Are there other ways to ensure transmitted data is not modified or tampered with?
- Are there additional legal requirements or benefits to securing caller identity throughout the call path?
- FCC also seeks comment on whether to require the current version of RCD standards, how to balance evolving standards with implementation timelines, and whether the standards are sufficiently developed to mandate use.
- To what extent have providers implemented earlier versions?
- Do newly finalized standards require more time to implement?
- Are additional features or functions still needed and how can work be completed in a timely way?
- FCC seeks Comment on the benefits and drawbacks of RCD overall
- FCC also seeks Comment on alternatives to RCD for transmitting caller identity information, such as call branding or branded calling solutions that may use RCD partially or in combination with other standards or proprietary elements
Calls Originating from Outside of the United States
The FCC proposes requiring providers to identify and mark calls originating outside the U.S.
- Propposes the gateway providers must label foreign-originated calls.
- The intermediate provider must transmit that information downstream
- The terminating providers must transmit an indicator to consumers’ handsets when they know or have reason to know a call is foreign-originated
- FCC seeks Comment on necessary implementation steps and following questions:
- Can gateway providers reliably identify a call’s country of origin?
- Should STIR/SHAKEN authentication encrypt foreign-origin indicators in the PASSporT?
- Should OrigID fields be used to denote foreign calls, potentially even with unique IDs by country?
- Should intermediate providers be required to pass OrigIDs intact
- Should providers modify number presentation for foreign-originated calls carrying U.S. NANP numbers?
- Should there be exemptions for roaming U.S. mobile/VoIP devices abroad?
- FCC proposes requiring voice service providers to include foreign-origin status in call-blocking analytics.
- FCC seeks Comment on countries generating high volumes of scam/unlawful calls
- How should foreign-origin indicators appear on devices without confusing users?
- Should a dedicated area code for foreign-originated calls be established?
- Should gateway providers block foreign-originated calls with NANP numbers outside any designated foreign-use area code?
- FCC is considering prohibition on spoofing US numbers for foreign-originated calls:
- Does this mislead consumers?
- How many spoofed calls are lawful v. unlawful?
- Would banning encourage jobs to return to U.S.?
- What effect on NANP member countries?
- Should spoofing and foreign-origin controls be addressed in MOUs or agreements?
- Should call treatment differ based on whether the origin country has an agreement with the U.S.?
Discussion of Significant Alternatives Considered That Minimize the Significant Economic Impact on Small Entities
The FCC is seeking comment on ways to reduce burdens on small entities
- One proposal is to make caller ID requirements apply only when a terminating provider chooses to display A-level attestation indicators on consumers’ devices
- This would give small providers flexibility – if they do not display attestation they would not be subject to the associated caller ID requirements
The NPRM has yet to be published. The Comment Date will be 30 days after date of publication in the Federal Register; Reply Comment Date is 60 days after date of publication in the Federal Register; the Deadline for Responses to Public Notice: 45 days after publication in the Federal Register. And the open meeting is on October 28, 2025.
And as you’d expect, Troutman Amin, LLP will be hosting our own webinar to break down the key impacts on this NPRM Tuesday October 14, 2025.
See you soon!
xoxo
Queenie