Tired of receiving recurrent robocalls, worried about your family or friends getting taken in by a Medicare Advantage, funeral expense or other robocall-marketed scammer, or frustrated about business headaches your business experiences from robocallers spoofing its number? Use this link to tell the Federal Communications Commission (“FCC”) to adopt the “Know Your Customer” and other tighter robocall rules the FCC proposed in the Combatting Illegal Robocalls Through FCC Numbering Policies; Combatting Illegal Robocalls through FCC Numbering Policies, Implementation of TRACED Act; Section 6(a) — Knowledge of Customers by Entities with Access to Numbering Resources; Numbering Policies for Modern Communications, Telephone Number Requirements for IP-Enabled Service Providers Notice of Proposed Rulemaking – WC Docket Nos. 26-49, 20-67, 13-97, 07-243.
The proposed “Know Your Customer” rules are part of regulation reforms the FCC is considering adopting to better protect Americans against robocall scams and other abuses.
The FCC proposes strengthening “Know Your Customer” requirements for voice service providers to combat illegal robocalls by requiring stricter vetting of customers and upstream providers by voice services providers. Voice services providers would be required to use rigorous, standardized customer-verification procedures.
These proposals build on existing requirements for providers to assign Attestation Levels and respond to Traceback Requests within 24 hours.
The proposed proposed rules aim to close loopholes illegal, foreign-originated , scammers often use to enter the network.
Key Aspects of the Proposed Rules include the following:
- Voice providers must take affirmative measures to know their customers and verify they are not using the network for illegal traffic.
- The proposal aims to stop illegal calls at the source, particularly focusing on providers that act as gateways for international scam calls.
- The FCC is set to vote on these tightened regulations to ensure all telecom network providers follow strict “Know Your Customer” principles.
In connection with its consideration of these other proposed changes, the FCC is inviting public comment, including input on the following:
- Whether to adopt changes to its numbering policies with respect to how assigned numbering resources are utilized, reported, and resold by service providers as part of its continuing effort to combat illegal robocalls. The Notice would explore and propose a broad array of solutions to strengthen the Commission’s numbering requirements and policies, particularly as they relate to resellers that use numbering resources to engage in some of the most extensive illegal robocalling schemes.
- Whether to extend further the FCC’s robocall certification requirements that are currently applicable to interconnected VoIP providers with direct access to numbers to all service providers that receive numbering resources directly from the North American Numbering Plan Administrator, and also to resellers.
- Seek comment on proposals to modify the number utilization reporting requirements in the numbering resource utilization/forecast form to aid robocall enforcement efforts, obtain more granular information regarding utilization, better detect irregularities, and inform numbering policy development.
- Seek comment on restricting numbering resale to a single level to avoid masking the parties in interest that may be responsible for illegal robocalls, as well as the parties with relevant data, which can occur when there are multiple levels of resale.
- Seek comment on how the Commission’s numbering policies can and should address illegal robocallers that rely on number “cycling”—going through large quantities of telephone numbers on a rotating, or single-use basis to evade robocall detection.
- Seek comment on new ways in which the Commission, with assistance from the states and the NANPA, can better identify fraudulent use and misuse of telephone numbers.
- Seek comment on other changes that could safeguard against abuse of numbering resources to promote efficient use of finite numbering resources and to further deter robocalling.
Industry organizations that would be impacted by these tighter restrictions already are well aware of the requirements and providing their comment about the proposals. As historically the comments and input on these and other similar proposals are predominantly submitted by industry, representatives, prior proposals to require regimented certification and other proposals to impose tighter obligations on the telecommunications and VOIP generally have been significantly watered down or not adopted.
Public comment and support of these or other safeguards is critical to ensure that the FCC receives the public input necessary to support these and other proposals to tighten the rules to better protect the public against the Robocall threat.
The simplest way to submit comments is to use the FCC comment portal here.
The author of this update, Cynthia Marcotte Stamer has decades of experience advising and representing governmental and private entities, about the wide range of legislative and regulatory affairs, government relations, and other legal, compliance, risk management and other operational and enforcement matters. If you have questions or need advice or help evaluating or addressing these or other compliance, risk management, or other concerns, contact her.
For More Information
We hope this update is helpful. For more information about these or other legal, contractual or operational compliance or risk management, please contact the author Cynthia Marcotte Stamer via e-mail or via telephone at (214) 452-8297.
Solutions Law Press, Inc. invites you receive future updates by registering on our Solutions Law Press, Inc. Website and participating and contributing to the discussions in our Solutions Law Press, Inc. LinkedIn SLP Health Care Risk Management & Operations Group, HR & Benefits Update Compliance Group, and/or Coalition for Responsible Health Care Policy.
About the Author
Recognized by her peers as a Martindale-Hubble “AV-Preeminent” (Top 1%) and “Top Rated Lawyer” with special recognition LexisNexis® Martindale-Hubbell® as “LEGAL LEADER™ Texas Top Rated Lawyer” in Health Care Law and Labor and Employment Law; as among the “Best Lawyers In Dallas” for her work in the fields of “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law” by D Magazine, Cynthia Marcotte Stamer is a practicing attorney board certified in labor and employment law by the Texas Board of Legal Specialization and management consultant, author, public policy advocate and lecturer widely known for her more than 35 years of health industry and other management work, public policy leadership and advocacy, coaching, teachings, and publications including leading edge work on workforce and other risk management and compliance.
Ms. Stamer’s work throughout her career has focused heavily on working with businesses domestically and internationally on employment, benefits, technology, data confidentiality, privacy, and security, and other Federal Sentencing Guidelines and other workforce management, regulatory and public policy and other legal and operational concerns.
A primary consultant to the government of Olivia on its pension privatization law, miss Stamer also has decades of experience working on legislative and regulatory advocacy on telephone and other voice regulations, labor and employment, employee, benefits, technology, immigration, privacy, and data, security, tax, insurance, workers compensation, and occupational injury, antitrust, agriculture, and a diverse range of other laws and regulations.
Author of many highly regarded compliance, training and other resources on these and other operations, risk management, compliance and government affairs concerns, Ms. Stamer is widely recognized for her thought leadership and advocacy on these matters.
In addition, Ms. Stamer currently or previously served as the American Bar Association (“ABA”) Joint Committee on Employee Benefits OCR annual agency scribe and a Council Representative, International Section International Employment Law Committee Chair and International Life Sciences and Health Committee Chair, ABA TIPS Medicine and Law Committee Chair, ABA Health Law Section Managed Care & Insurance Interest Group Chair, former Vice President and Executive Director of the North Texas Health Care Compliance Professionals Association, past Board President of Richardson Development Center (now Warren Center) for Children Early Childhood Intervention Agency, past North Texas United Way Long Range Planning Committee Member, and past Board Member and Compliance Chair of the National Kidney Foundation of North Texas, and a host of other professional and civic leadership roles. She is a Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation, Ms. Stamer also shares her extensive publications and thought leadership as well as leadership involvement in a broad range of other professional and civic organizations.
For more information about Ms. Stamer or her health industry and other experience and involvements, see www.cynthiastamer.com or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.
About Solutions Law Press™
Solutions Law Press™ provides health care, human resources and employee benefit and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education on health care, leadership, governance, human resources, employee benefits, data security and privacy, insurance, and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press™ resources.
If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating your profile here.
NOTICE: These statements and materials are for general information and purposes only. They do not establish an attorney-client relationship, are not legal advice or an offer or commitment to provide legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation considering the specific facts and circumstances presented in their unique circumstance at the particular time. No comment or statement in this publication is to be construed as legal advice or admission. The author reserves the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law constantly and often evolves, subsequent developments that could impact the currency and completeness of this discussion are likely. The author and Solutions Law Press, Inc. disclaim and have no responsibility to provide any update or otherwise notify anyone of any fact or law specific nuance, change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.
Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.
©2026 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press, Inc.™ For information about republication, please contact the author directly. All other rights reserved.