Today, a Further Notice of Proposed Rulemaking (“FNPRM”) adopted by the Federal Communications Commission (“FCC”) at its open meeting on October 28, 2025, was published in the Federal Register, kicking off the comment cycle for the issues raised in that FNPRM.  Comments on the FNPRM are due January 5, 2026, and reply comments are due February 3, 2026.

The FNPRM focuses on proposals intended to enhance the accuracy of caller ID information to help curb illegal robocalls, particularly those originating from outside of the U.S.  It also seeks comment on a range of proposed changes to existing FCC rules pertaining to the Telephone Consumer Protection Act (“TCPA”).  

With respect to Caller ID, the FNPRM seeks comment on the following key proposals:

  • Defining “Caller Identity Information.”  The FNPRM proposes that the term “caller identity information” have the same meaning as “caller identification information” under the FCC’s rules, except it would not require that “the originating telephone number or portion thereof and billing number information” be provided.
  • Sharing Caller Identity Information with Consumers.  The FNPRM seeks comment on a range of proposals aimed at ensuring that consumers receive verified caller ID information, such as requiring originating providers to verify the accuracy of the caller ID information transmitted to consumers.  The FNPRM also seeks comment on establishing a minimum standard for what caller ID information consumers must receive and how to ensure the secure transmission of this information to the called party. 
  • Calls Originating from Outside of the U.S. To address a significant source of illegal calls, the FNPRM seeks comment on: (1) requiring voice service providers to employ “reasonable analytics” to detect and block calls from callers outside of the United States; (2) whether to establish a “designated area code” or another phone numbering requirement; and (3) requiring providers to identify calls that originate outside of the U.S. when they “know or have reason to know” such information. 

With respect to TCPA reform, the FNPRM seeks comment on the following: 

  • Call Abandonment Rules.  Currently, the FCC’s rules require callers to wait at least 15 seconds, or 4 rings, before disconnecting from an unanswered telemarketing call and prohibits “abandoning more than 3% of all telemarketing calls.”  The FNPRM seeks comment on whether these rules are still necessary given the modern communications environment.  
  • Artificial and Pre-Recorded Voice Caller Identification Rules. Currently, the FCC’s rules require all artificial or pre-recorded voice callers to include a telephone number, one that is not a 900 number or any number where charges to the individual exceed local or long-distance transmission rates.  The FNPRM seeks comment on whether this rule should be narrowed to require only that the telephone number used identifies for consumers who is calling them.
  • Consent Revocation Rules.  Currently, the FCC’s rules require callers to “treat an opt-out request made in response to one type of call to be an opt-out request for all types of calls.” Senders also are prohibited from designating an exclusive means for recipients to revoke consent; instead, senders must honor opt-out requests submitted through any “reasonable means.”  The FNPRM seeks comment on whether (or how) the “opt-out request for all types of calls” or “revoke all” provision should be modified and whether an exclusive method for honoring such requests should be permitted.  Alternatively, the FNPRM asks whether more concrete and less restrictive alternatives exist to replace the current “reasonable means” standard for honoring opt-out requests.  
  • Fraud Alert Rules.  Currently, the FCC’s rules require financial institutions to only call telephone numbers provided by consumers when alerting them about potential fraud (or when calls fall under the financial institutions exception to the “prior express consent” requirement).  The FNPRM seeks comment on whether financial institutions should be allowed to provide consumers with fraud alerts via the multiple numbers belonging to or associated with that consumer.
  • Call Blocking Rules.  Currently, the FCC’s rules allow “voice service providers to block calls that are on a do-not-originate list or that purport to be from a NANP number that is invalid, unallocated, or unused.”  The FNPRM seeks comment on whether these rules should be eliminated, as other FCC rules that have yet to take effect will impose the same obligations on voice service providers.

Tags: Consumer Protection, FCC, Federal Communications Commission, Robocall, TCPA
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Photo of Yaron Dori Yaron Dori

Yaron Dori has over 25 years of experience advising technology, telecommunications, media, life sciences, and other types of companies on their most pressing business challenges. He is a former chair of the firm’s technology, communications and media practices and currently serves on the…

Yaron Dori has over 25 years of experience advising technology, telecommunications, media, life sciences, and other types of companies on their most pressing business challenges. He is a former chair of the firm’s technology, communications and media practices and currently serves on the firm’s eight-person Management Committee.

Yaron’s practice advises clients on strategic planning, policy development, transactions, investigations and enforcement, and regulatory compliance.

Early in his career, Yaron advised telecommunications companies and investors on regulatory policy and frameworks that led to the development of broadband networks. When those networks became bidirectional and enabled companies to collect consumer data, he advised those companies on their data privacy and consumer protection obligations. Today, as new technologies such as Artificial Intelligence (AI) are being used to enhance the applications and services offered by such companies, he advises them on associated legal and regulatory obligations and risks. It is this varied background – which tracks the evolution of the technology industry – that enables Yaron to provide clients with a holistic, 360-degree view of technology policy, regulation, compliance, and enforcement.

Yaron represents clients before federal regulatory agencies—including the Federal Communications Commission (FCC), the Federal Trade Commission (FTC), and the Department of Commerce (DOC)—and the U.S. Congress in connection with a range of issues under the Communications Act, the Federal Trade Commission Act, and similar statutes. He also represents clients on state regulatory and enforcement matters, including those that pertain to telecommunications, data privacy, and consumer protection regulation. His deep experience in each of these areas enables him to advise clients on a wide range of technology regulations and key business issues in which these areas intersect.

With respect to technology and telecommunications matters, Yaron advises clients on a broad range of business, policy and consumer-facing issues, including:

Artificial Intelligence and the Internet of Things;
Broadband deployment and regulation;

IP-enabled applications, services and content;
Section 230 and digital safety considerations;
Equipment and device authorization procedures;
The Communications Assistance for Law Enforcement Act (CALEA);

Customer Proprietary Network Information (CPNI) requirements;

The Cable Privacy Act
Net Neutrality; and
Local competition, universal service, and intercarrier compensation.

Yaron also has extensive experience in structuring transactions and securing regulatory approvals at both the federal and state levels for mergers, asset acquisitions and similar transactions involving large and small FCC and state communication licensees.

With respect to privacy and consumer protection matters, Yaron advises clients on a range of business, strategic, policy and compliance issues, including those that pertain to:

The FTC Act and related agency guidance and regulations;
State privacy laws, such as the California Consumer Privacy Act (CCPA) and California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, and the Utah Consumer Privacy Act;
The Electronic Communications Privacy Act (ECPA);
Location-based services that use WiFi, beacons or similar technologies;
Digital advertising practices, including native advertising and endorsements and testimonials; and

The application of federal and state telemarketing, commercial fax, and other consumer protection laws, such as the Telephone Consumer Protection Act (TCPA), to voice, text, and video transmissions.

Yaron also has experience advising companies on congressional, FCC, FTC and state attorney general investigations into various consumer protection and communications matters, including those pertaining to social media influencers, digital disclosures, product discontinuance, and advertising claims.

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Kiara Ortiz

Kiara Ortiz is an associate in the firm’s Washington, DC office. She is a member of the Technology and Communications Regulation Practice Group.

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Travis Cabbell is an associate in the firm’s Washington, DC office. He is a member of the Commercial Litigation Group and the Technology and Communications Regulation Practice Group.

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