“THESE CALL CENTERS ARE SECURE”: CTIA Crushes FCC Assumptions Regarding Foreign Call Centers and Takes Aim at Commission NPRM Proposal in Aggressive Reply Comment

The CTIA usually plays nice with the FCC. After all the CTIA’s members are heavily regulated by the Commission and draw much of their power from the FCC permitting various wanton acts of cartel by the CTIA and the carriers it represents.

But the CTIA did not hold back AT ALL in launching on the FCC’s new onshoring NPRM and it is remarkable to see.

As TCPAWorld readers know the FCC recently issued an NPRM looking to limit American businesses from using offshore call centers for both inbound and outbound operations. The NPRM may require businesses to advise consumers when their calls may be handeled or come form an offshore call center and allow consumers the option to select to hear from an American cell center instead.

The FCC’s NPRM was built on the beleif that Americans do not like foreign call centers and on findings suggesting that offshore call centers are full of thick-accented foreigners in exotic locations that cannot be trusted to effectively communicate with Americans or keep their private information safe from scammers.

Well the CTIA took offense to this entire jaundiced caricature of offshore call centers and hit back with stats showing America customers actually receive better experiences from offshore centers:

Commenters agree that the NPRM’s proposals are based on unfounded assumptions about the state of customer service operations—namely, that the quality of customer service conducted offshore is diminished. Both wireless stakeholders and commenters representing other industries report that customer satisfaction is as good, if not better, when calls are handled by offshore call centers.2 The record demonstrates vigorous competition and the innovative ways that communications providers are evolving their practices to better engage with their customers, including through extended availability, calls, chats, and other means of communication that are only possible because these providers can apply a “follow-the-sun” approach to customer service, which leverages operational efficiencies to serve customers from call centers around the world.

The CTIA goes on to argue foreign call centers are secure despite the FCC’s misgivings:

These call centers are secure. Stakeholders across the communications sector implement consistent industry best practices and comply with strict standards across both their domestic and offshore call center operations. The record is replete with evidence that adoption of the proposals would not improve the consumer experience, and in fact, would result in higher costs, longer wait times, and other harms to consumers. Indeed, some proposals would require duplication of call center staff resources resulting in substantial costs estimated to be more than $6.3 billion initially, with at least $1.8 billion in annual recurring costs for the wireless industry alone. In short, the proposals are solutions in search of problems and are not supported by the realities of the customer service ecosystem or record evidence.

The Comment also does a nice job cataloging evidence in the record supporting its claims that consumers prefer the experience of foreign call centers:

Comments of CTIA, CG Docket Nos. 26-52, 17-59, 02-278, 22-2, at 12–13 (filed June 2, 2026) (“CTIA
Comments”) (“Contrary to the unfounded assertions in the NPRM, some wireless industry stakeholders
report that customer satisfaction is as good, if not better, when calls are handled by offshore call
centers.”); Comments of ACA International, CG Docket Nos. 26-52, 17-59, 02-278, 22-2, at 18 (filed
June 2, 2026) (“ACA International Comments”) (“Studies comparing the results of [customer
satisfaction] metrics reflect that nearshore and offshore call centers typically perform as well as, if not
better than, their domestic counterparts.”); Comments of Service Contract Industry Council, CG Docket
Nos. 26-52, 17-59, 02-278, 22-2, § 4 (filed June 2, 2026) (“SCIC Comments”) (“One of the larger SCIC
member companies – with over 90 million customers – observes that their offshore call centers achieve
higher customer satisfaction scores than their domestic counterparts; hence a very real and material
unintended consequence of the rule will be to adversely impact customer services, therefore customer
retention.”); Comments of USTelecom, CG Docket Nos. 26-52, 17-59, 02-278, 22-2, at 5–6 (filed June 2,
2026) (“USTelecom Comments”) (“[O]ne USTelecom member that handles a majority of customerservice calls overseas reported that its Net Promoter Score for its call-center activities is at an all-time
high. Another USTelecom member reported that its Net Promoter Score is consistently higher for
overseas call-centers than its domestic counterparts. Post-call customer surveys tell a similar story.
According to a third USTelecom member, its customers report that the call-center representative resolved
the customer’s reason for calling 12% more often when the call was handled by an offshore agent, as
compared to calls handled by an onshore agent.” (emphasis omitted) (footnote omitted)).

This is all really good stuff.

Surprised to see CTIA taking such an aggressive stance here. Will be interesting to see what the Comission does with all of this.

Comment was submitted by

Sarah Leggin
Vice President, Regulatory Affairs
Umair Javed
Senior Vice President and General Counsel
Scott K. Bergmann
Senior Vice President, Regulatory Affairs
Courtney Tolerico
Director, Regulatory Affairs

Although I don’t always agree with everything CTIA does (to say the least) this was good work. You four should take a bow.

You can read full comment here: CTIA

Chat soon.