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In this week’s Research Assistant Peer Group call we discussed the Notice of Proposed Rule Making (NPRM) the FCC has called Improving Consumer Service and Protecting Consumers Through Onshoring released 4-23-2026. Comments were due May 26, 2026.  

If you missed the comment period, it is still important to review the NPRM. While it is commendable that the FCC wants to reduce consumer harm from scams and potentially increase American jobs, many industry professionals feel this is not the best way to accomplish those goals. Looking for ways to help legitimate call centers improve compliance and performance is understandable, but burdening American companies with overly broad operational requirements and costs is another matter entirely.  

Let’s face it, criminals do not follow laws. Adding more restrictions that create operational nightmares for legitimate companies will not solve the problem. In the proposal, the FCC openly discusses making illegal calls more expensive in hopes of deterring them in the first place. The NPRM references potential bond requirements and fees for offshore calls. Unfortunately, those added costs are far more likely to impact legitimate businesses than bad actors. The reality is that many businesses utilizing call centers simply cannot afford to replace offshore agents with domestic labor.  

There is also another likely consequence that deserves attention. If companies are forced to reduce or eliminate offshore staffing, many will look for alternative ways to maintain contact operations. In many cases, that may mean turning to AI agents rather than hiring domestic workers. 

AI agent technology is still evolving, and businesses are actively working through the legal, regulatory, operational, and policy challenges that come with it. While AI agents are limited in some areas where human representatives still perform better, they are also cost-effective and capable of handling a significant portion of customer interactions. 

When reviewing the questions raised throughout the NPRM and applying them to real-world business operations, it becomes clear that these proposals could negatively impact many industries, not just debt collection. Some businesses could be overwhelmingly affected, with little evidence that the changes would meaningfully reduce scams or create substantial American jobs. 

The NPRM also discusses potentially expanding these concepts beyond voice communications to include non-voice channels such as text messages, chats, and emails when foreign-based staff are involved. The FCC further asks questions regarding VoIP and other internet-based communication providers. 

In this writer’s opinion, instead of overburdening legitimate businesses and intentionally driving up operational costs in hopes that scammers will eventually give up, regulators should focus more heavily on identifying and stopping the bad actors directly. 

That means investing in better technology to detect scams and locate scammers earlier, improving the sharing of scam-related information, and strengthening systems that allow consumers and businesses to report suspicious activity quickly. It also means pursuing and prosecuting bad actors aggressively with penalties severe enough to serve as real deterrents, not a slap on the hand, and they are back to business as usual. In short, go after the problem, not the legitimate companies trying to comply with the law. 

History has shown that when regulations become overly burdensome, bad actors typically find workarounds within months, sometimes even days. The entities most affected are usually the legitimate businesses making good-faith efforts to comply. Increased operational costs inevitably lead to costs often passed on to consumers. In the long run, that helps no one. 

It is also worth noting that this is not the first attempt to address offshore call center operations. In the past, at least three legislative bills on this subject have been introduced and failed. The FCC pursuing the issue through regulatory action may lead to a different outcome, or the final rules may ultimately become far less burdensome than the current NPRM suggests. 

If you have already submitted comments, thank you. If you missed the deadline, it is still encouraged to keep a close eye on this issue if your business is currently using, or plans to use, offshore agents. Staying informed is in your best interest. 

PDF of the NPRM 


Documents and Crowdsourced Materials:   


Top Reads:   


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