As followers of TCPAWorld know the FCC has several critical telecom NPRMs pending, rulings on which may turn everything we know about how phone calls are made to American consumers on its head.
First up is the foreign call center NPRM. In that NPRM the Commission is examining whether to:
- Limit the use of foreign call centers by American businesses in connection with both inbound and outbound calls;
- Impose training requirements on employees of offshore call centers; and
- Requiring notification to consumers a call is originating from or being directed to a foreign call center and whether consumers should be empowered to request a transfer to an American call center.
The overall tone of the NPRM is that foreign call centers are less effective, less trustworthy and deliver a negative consumer experience.
Responding for the lead generation industry, Responsible Enterprises Against Consumer Harassment (R.E.A.C.H.) pushed back against this narrative this week noting that offshore call center employees may be better trained, more responsive, longer tenured and happier than American employees resulting in better customer experiences.
You can read the entire comment here:
In the Comment R.E.A.C.H. requests the commission: Call Center Comment
- Clarify, in the context of the NPRM, who the regulated “providers” of telecommunication services would be;
- Not presume that all offshore call center interactions result in inferior consumer experiences;
- Focus on identifying and penalizing specific foreign call centers that knowingly utilize unlawful practices, rather than adopting a broad approach, or alternatively focus any broader approach on the jurisdictions from which those calls originate;
- Recognize that offshore call centers often provide businesses with a more stable, better trained, and longer tenured workforce than many domestic call centers;
- Do not broadly restrict or ban offshore call centers as doing so would likely accelerate the replacement of human customer service with AI systems that humans neither prefer nor trust;
- If disclosure requirements are imposed, they should be clear, specific, and designed to provide consumers with meaningful information;
- Provide a compliance period of at least 18 months; and
- Keep reporting requirements minimal and automated; and
Overall R.E.A.C.H. is pleased to be representing the industry on this critical issue and believes its comment will help assure businesses large and small are protected from needless government regulation and senseless limitations on business operations that benefit consumers.
For more information on R.E.A.C.H. and its mission to end unwanted robocalls while assuring a safe and sustainable telecom infrastructure for all visit REACHMBC.com.

