Regulatory Report: February 2025

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

March 2025 Holiday Solicitation Bans 

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

1. On Tuesday, March 4, 2025, the states of Alabama (Mobile and Baldwin counties only) and Louisiana prohibit unsolicited sales and marketing calls in observance of Mardi Gras.

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

Please be aware of the following Canadian holiday telephone solicitation bans for the month of March 2025: 

1. On Monday, March 17, 2025, unsolicited marketing calls are prohibited to residents of the provinces of Newfoundland and Labrador in observance of St. Patrick’s Day.

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

New York State of Emergency extended through March 16, 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 28.23, declaring a disaster emergency in the state of New York, has been extended through March 16, 2025. This order is regarding the Introduction of Non-Citizens from Countries Where a Quarantinable Communicable Disease Exists.   

Executive Order 46, declaring a state of emergency due to significant snowstorms and hazardous conditions, is effective through March 16, 2025. 

Gryphon has extended State of Emergency blocks for New York to March 16, 2025, to ensure compliance with the above Executive Orders.   

Reminder: FCC’s Revocation of Consent Rule Goes into Effect April 11, 2025

The FCC’s revocation of consent rule goes into effect April 11th. Are you prepared? 

Key points to remember: 

• The timeline for honoring a consumer’s request to opt out of communications decreases from 30 days to 10 business days (14 calendar days, which now aligns with CAN-SPAM for email) 

• The nuance of how to apply the revoked consent hinges on the type of message originally deployed (marketing vs. informational content) 

• A one-time, non-promotional revocation message is allowed (no response = “opt out all”) 

• Consumers must be able to revoke consent through any “reasonable” means 

Learn how to comply with this new requirement here. 

New State-Level Telemarketing Legislative Activity and a Newly Proposed AI TCPA Requirement 

It’s still early into 2025 and there has already been significant volume and velocity of proposed parameters influencing telemarketing calls and texts. 

At the federal level, the continued focus on Artificial Intelligence (AI) with respect to the TCPA has not wavered. United States HR 1027, sponsored by Eric Sorensen (Illinois), was introduced on February 5, 2025, and referred to the House Committee of Energy and Commerce on the same day.  

Details: 

• The bill aims to amend the Communications Act of 1934 

• Requires “robocalls” using AI to disclose use of AI at beginning of call 

• Proposes increased penalties for violations involving AI voice or text message impersonation 

Additionally, nine states have initiated a whirlwind of telemarketing-impacting bill activity to kick off 2025: 

• Arizona HB 2342: mandates blocking spam/fraud calls and calls made from dialer software 

• Illinois HB 1730: this “Stop Spoofing Law” prohibits misleading or inaccurate caller ID information transmitted via voice or VoIP and establishes a website where residents can report Caller ID incidents 

• Illinois HB 2435: amends the Telephone Solicitations Act, prohibiting telemarketing calls using automatic dialing, autodialers, or a computer program designed to mimic a human operator without consent.  

• Maryland HB 107; SB 49: companion bills requiring clear disclosure of automatic renewal terms, straightforward cancellation options, advance notification of renewals, and prohibiting automatic charges without proper notice, with violations classified as unfair trade practices. 

• Massachusetts HD 2198; SD 359: companion bills amending telemarketing laws, allowing businesses to register on Massachusetts’ No-Call list 

• Missouri HB 292, SB 469: companion bills amending telemarketing laws, allowing businesses to register on Missouri’s No-Call list and to apply certain obligations (disclosures and caller ID) to B2B calls 

• Missouri HB 564: this “Caller ID Anti-Spoofing Act” enhances legislation allowing businesses to register on Missouri’s No-Call list, applying disclosures and caller ID requirements to B2B calls, and prohibiting callers from entering false caller ID information with the intent to deceive, defraud, or mislead the recipient of a call.  

• New York AB 1250: prohibits unsolicited telemarketing sales calls when a state of emergency or disaster emergency is declared only if the declaration includes a finding that such calls would impair actions taken to limit, control, or mitigate the emergency; the duration of the prohibition may only extend for two-week periods unless findings of necessity are made at the end of each two-week period 

• New York AB 1845: requires telemarketers to add a customer’s phone number to all their do-not-call lists if the customer requests to be added to any one of them 

• New York AB 2593: this Robocall Prevention Act amends telemarketing law prohibiting the use of equipment making calls to stored telephone numbers or using artificial or prerecorded voices without consent 

• New York SB 859: amends telemarketing law to prohibit calls or texts from using an artificial or prerecorded voice or automatic dialing device and requires telephone service providers to offer free call blocking technology to their customers 

• Virginia SB 1339: this “Virginia Telephone Privacy Protection Act” amends telephone solicitations law to clarify that a number used to send a text must accept reply opt-out messages and unsubscribe requests must be honored for at least 10 years. This bill was signed by the President on February 20, 2025. 

• Washington HB 1103: amends telemarketing law to expand prohibitions to text messages, which cannot be sent without prior express consent 

FCC’s February Open Meeting Agenda includes Vote on Call Blocking Report & Order 

Just five months after the Federal Communications Commission’s (FCC) September 3rd Text Blocking Order (using DNO List) went into effect, another Voice Service Provider (VSP) provision for call blocking has been proposed for adoption in February’s Open FCC meeting. 

The new Report & Order aims to enhance consumer protection by reducing the volume of illegal calls and ensuring that legitimate calls are not erroneously blocked.  

The draft version of the 8th Report & Order (released on February 6, 2025), contains the following requirements: 

1. Blocking Based on a Reasonable Do-Not-Originate (DNO) List 
   • Requirement: All VSPs service providers must block calls that are highly likely to be illegal based on a reasonable DNO list.
   • Description: This list includes numbers that are invalid, unallocated, unused, or numbers for which the subscriber has requested blocking. This measure aims to prevent illegal calls from reaching consumers by ensuring that all providers in the call path participate in blocking these calls. 
2. Immediate Notification of Analytics-Based Blocking 
   • Requirement: VSPs must use Session Initiation Protocol (SIP) code 603+ for immediate notification when calls are blocked based on reasonable analytics. 
   • Description: SIP code 603+ provides detailed information to callers about why their call was blocked and includes contact information for redress. This ensures transparency and helps correct any erroneous blocking quickly. 
3. Protections for Lawful Calls 
   • Requirement: VSPs must ensure transparency and redress for callers whose calls are blocked in error. 
   • Description: This includes providing a point of contact for blocking disputes, status updates within 24 hours, and ensuring that emergency calls (e.g., 911) are not blocked. VSPs must also produce a list of blocked calls upon request. 

The FCC declined to adopt a safe harbor for blocking based on a reasonable DNO list “because it is unclear what liability a provider would face for blocking based on such a list and we are unaware of any provider facing such liability since the Commission first authorized this blocking in 2017.” 

If adopted, VSPs have 12 months from the publication of the order in the Federal Register to implement the new SIP code 603+, ensuring compliance with the new requirements. 

Telnyx Fined $4.5 Million by FCC for Imposter Robocalls 

On February 4, 2025, in the first Federal Communications Commission (FCC) action under new Chairman Brendan Carr, a fine for $4,492,500 was proposed against Telnyx LLC for failing to exhibit “Know Your Customer” standards (KYC = a Stir-Shaken obligation), allowing malicious actors to originate illegal voice traffic on their network. 

The FCC does not have a named “Fraud Prevention Team,” however, on February 6 and 7, 2024, FCC staff and family members received an artificial prerecorded voice message robocalls on their personal and work phones, stating this special FCC “team” would like to speak with them. One recipient of an imposter call reported that they were ultimately connected to someone who “demand[ed] that [they] pay the FCC $1000 in Google gift cards to avoid jail time for [their] crimes against the state.” 

“Cracking down on illegal robocalls will be a top priority at the FCC,” said FCC Chairman Brendan Carr. 

The FCC’s Notice of Apparent Liability for Forfeiture (NAL) is not a final FCC action but rather alleges violations of the law with proposed sanctions. Telnyx will be given an opportunity to respond. 

FCC Chairman Brendan Carr Announces Additional Staff Appointments 

In a public announcement, Carr welcomed the following new staff members, all of which have extensive experience in both government and private sectors, with significant roles at the FCC or related agencies: 

• Adam Candeub, General Counsel of the FCC  

• Jay Schwarz, Chief, Space Bureau 

• Adam Jackman, Director of Strategic Communications, Office of Media Relations 

• Dana Howell, Executive Assistant, Office of Chairman Brendan Carr 

Additional staff appointment announcements will follow. 

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.