Gryphon Regulatory Report:
December 2024

Below is a recap of essential regulatory updates for contact compliance professionals for the month of December. 

Just a reminder, one-to-one consent requirements go into effect on January 27, 2025. Check out our recent blog post on how to prepare for the upcoming changes. 

Update Regarding U.S. Holiday Telephone Solicitation Bans for December 2024  

By executive proclamation, the Governor of Louisiana declares December 31, 2024, a legal holiday and a day of rest.  

On Tuesday, December 31, 2024, the state of Louisiana prohibits unsolicited sales and marketing calls in observance of this holiday proclamation.  

Gryphon has updated its existing service parameters to reflect this additional solicitation ban.   

See the official proclamation here.  

January 2025 Holiday Solicitation Bans  

Please be aware of the following U.S. holiday telephone solicitation bans for the month of January 2025:  

1. On Wednesday, January 1, 2025, the states of Alabama, Louisiana, Nebraska*, Pennsylvania, Rhode Island, and Utah prohibit unsolicited sales and marketing calls in observance of New Year’s Day.  

1. On Monday, January 20, 2025, the states of Alabama, Louisiana, Nebraska*, Pennsylvania, Rhode Island, and Utah prohibit unsolicited sales and marketing calls in observance of Martin Luther King Jr. Day (in Alabama, Monday, January 20th is referred to as Martin Luther King Jr. and Robert E. Lee’s Birthday). 

Other holidays may be proclaimed by the Governor in each state throughout the year.  

*Nebraska does not prohibit calls on Sundays or legal holidays. However, it does restrict the use of prerecorded messages to 1 pm to 9 pm on these days (subject to certain exceptions).  

Please be aware of the following Canada holiday telephone solicitation bans for the month of January 2025:  

1. On Wednesday, January 1, 2025, all Canadian provinces and territories prohibit unsolicited sales and marketing calls in observance of New Year’s Day.  

Gryphon has updated its existing service parameters to reflect these solicitation bans. 

New York State of Emergency Declared Through January 10, 2025  

Consistent with prior communications, Executive Orders declaring disaster emergencies in the State of New York trigger telemarketing restrictions under the Nuisance Call Act.    

The Nuisance Call Act makes it unlawful for any telemarketer to make unsolicited telemarketing sales calls to areas of the state under an emergency declaration.      

Executive Order 28.21, declaring a disaster emergency in the state of New York, remains in effect through January 19, 2025. This order is regarding the Introduction of Non-Citizens from Countries Where a Quarantinable Communicable Disease Exists.   

Executive Order 38.4 for a weather-related disaster emergency for all counties in New York, remains in effect through December 27, 2024.   

Executive Order 43 declares a state of emergency for 12+ New York counties for a severe storm system and hazardous conditions, through January 10, 2025.  

Gryphon has extended State of Emergency blocks for New York to January 19, 2025, to ensure compliance with the above Executive Orders.    

FTC Adopts Final TSR Rule for Inbound Telemarketing Tech Support Calls  

In April 2024, the Federal Trade Commission (FTC) sought public comment on the Telemarketing Sales Rule (TSR) proposal extending coverage to inbound tech support calls, reported as defrauding consumers 60 and older of more than $175 million in losses within the last year. See this FTC report to Congress on protecting older consumers.  

A tech support scam is a type of fraud where scammers trick people into calling them for fake technical support. They use fake alerts (pop ups or messages on your computer or phone, claiming there’s a serious problem or virus), using urgency to encourage calling for immediate help – which is also phony. The scammers steal money or personal information, often asking for payment through hard-to-reverse methods like gift cards, wire transfers, or cryptocurrency.  

On November 27th, the FTC approved final TSR amendments extending coverage to inbound tech support calls, and it was published in the Federal Register on December 10th.   

The amendments are effective January 9, 2025.  

FCC Adopts Rules Strengthening Caller ID Requirements for Third-Party Authentication Solutions  

“Scammers falsify caller ID information to deceive call recipients into believing they are trustworthy.”   

On November 21st, the Federal Communications Commission (FCC) adopted the 8th Report & Order as part of ongoing efforts to curb illegally spoofed robocalls and maintain consumer protection, with new service provider requirements around third-party authentication.  

Caller ID information must be verified by the service provider, either by meeting STIR/SHAKEN IP protocols, or by relying on third parties for authentication.  

Under new rules, two conditions must be met:  

1. Compliance with STIR/SHAKEN Technical Standards: Service providers remain responsible and accountable for ensuring attestation-level decisions made by the third party align with the STIR/SHAKEN technical standards.  

1. Use of Service Provider’s Credentials: Any calls authenticated by the third party must use the service provider’s Service Provider Code (SPC) token and digital certificate.  

These requirements aim to maintain the integrity of the STIR/SHAKEN framework and ensure accountability in the caller ID authentication process.  

See the FCC Press Release here.  

FCC Announces Robocall Mitigation Database Compliance Failures and Consequences  

The Federal Communications Commission’s (FCC) Robocall Mitigation Database (RMD) requires voice service providers to certify their efforts in combating illegal robocalls, including implementing the STIR/SHAKEN caller ID authentication framework. This database helps the FCC and law enforcement agencies track and enforce compliance, aiming to reduce the number of unwanted and fraudulent calls.  

On December 10th, in partnership with the 51-attorney general Anti-Robocall Multistate Litigation Task Force, the FCC’s Enforcement Bureau issued an order naming 2,411 voice service providers who “failed to file properly” in the RMD, and now, by December 31, 2024, “must show cause why they should not be removed” from the RMD.  

Also on December 10th, state prosecutors for New Hampshire and North Carolina issued warnings to voice service providers transmitting suspected robocalls in their respective states.  

The consequences for being removed from the RMD are steep and would require all intermediate providers and voice service providers to cease accepting all calls directly from the company.  

And that’s not all. Newly proposed FCC RMD rules include annual re-certification, $10,000 fines for submitting false or inaccurate information, and $1,000 for failure to keep information current.  

See the FCC Press Release here.  

About Gryphon.ai 

Staying updated with the latest regulatory changes is crucial for any enterprise aiming to minimize risk and maximize reach. Gryphon.ai is the only automatic, real-time, intelligent contact compliance solution on the market that delivers compliant, real-time intelligence into every customer conversation. 

With Gryphon.ai, enterprises can stay ahead of the regulatory curve and efficiently manage all regulatory changes, ensuring seamless compliance and operational excellence. 

To learn more about how Gryphon can help you manage these updates, reach out to us today.