Below is a recap of essential regulatory updates for contact compliance professionals for the month of March.
New York State of Emergency Updates
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, is effective 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 statewide New York state of emergency due to significant snowstorms and hazardous conditions, is effective through March 16, 2025.
Executive Order 38.7, declaring a New York statewide state of emergency due to significant rainfall, thunderstorms and flash flooding, has been issued through March 21, 2025.
Executive Order 47.2 has been issued declaring a State Disaster Emergency in the State of New York arising from an illegal and unlawful strike by correction officers and is effective through March 21, 2025.
Lastly, Executive Order 48, declaring a disaster in the county of Suffolk, New York for wildfires creating hazardous conditions and posing imminent danger, is effective through April 7, 2025.
Gryphon has extended State of Emergency blocks for New York to March 21, 2025 (April 7 for Suffolk County), to ensure compliance with the above Executive Orders.
FCC Adopts Call Blocking Report & Order in February Open Meeting
On February 27, 2025, during the Federal Communication Commission (FCC) open meeting, a unanimous 4-0 vote sealed the approval and adoption of the FCC 8th Report & Order, requiring two things:
- “Every company on the call path to stop calls on the ‘do not originate’ list, an expansion from the number that had to do so before.”
- “Creation of a special code for letting callers know if their call has been blocked, in case the calls are legitimate and were blocked by accident.”
Although currently not required, the FCC’s Report & Order also urges “providers to continue to develop next-generation tools, such as Rich Call Data (RCD) and branded calling solutions,” and further suggests this could become a future mandate if this evolution doesn’t occur organically.
FCC Chair Brendan Carr referred to robocalls as “scourge,” and Commissioner Geoffrey Starks voiced his preference for former Chair Rosenworcel’s “more robust version” placing similar rules on text messages, in addition to calls.
The impacted companies have 12 months from the publication of the order in the Federal Register to implement the new SIP code 603+ (and no other code), ensuring compliance with the new requirements.
Click here for the NPRM and FCC fact sheet.
TCPA Case Filings Are Up, But Class Action Cases Dominate TCPA Litigation
TCPA cases are on the rise, which is big news itself. But the activity around TCPA class action cases is almost hard to believe. Case in point, TCPA history was made in 2024 with the largest number of TCPA class action cases ever recorded as 2,788 TCPA cases were filed (up 67% from 2023).
With the TCPA case filing trajectory trending upwards throughout the year, it hit a peak in November 2024 with 1,088 cases filed in that month alone, and with a whopping 1,039 (95.5%) certified as class actions. While December numbers dropped, they were still higher than all other months in 2024 (except November) and reflected 85.3% class action filings to close out the year.
For comparison, 76% of all TCPA cases were class action lawsuits in 2024, up from 50-57% in previous years.
And so far, TCPA class action cases recorded in 2025 are showing no signs of relief.
TCPA class action cases:
- January 2024: 64
- January 2025: 172
- 268% year over year increase
With 207 total TCPA cases filed in January 2025, it’s up 8.4% compared to December 2024.
Keep in mind these TCPA cases were all filed before the FCC’s one-to-one consent rule was scheduled to take effect in January 2025 (the ruling has since been vacated), and it’s prior to the fallout we’ll likely see from the upcoming FCC Revocation of Consent rules, effective in just a couple of weeks on April 11th, which means these cases were filed on current TCPA rules and regulations.
It’s imperative that you acknowledge and stay current on core TCPA rules and regulations at the federal level as well as state level telemarketing laws and incorporate them into your business as applicable. It’s a lot, and it’s tough – we get it! But Gryphon.ai sets the standard in the contact compliance space, so let us help. It’s what we do well.
Source: WebRecon
United States HR 1027 “QUIET Act”
As mentioned in our February 2025 Regulatory Report Update, US HR 1027 was introduced by Representative Eric Sorenson (Illinois) to the House on February 5, 2025, and was referred to the House Committee of Energy and Commerce on the same day.
US HR 1027 is also known as the QUIET Act (Quashing Unwanted and Interruptive Electronic Telecommunications Act). The bill focuses on “increasing penalties for scammers” related to AI-driven robocalls and impersonation.
On February 6, 2025, Representative Sorenson asked and was given permission to address the House to revise and extend his remarks. His remarks were as follows:
“Mr. Speaker, across America, working families and seniors are feeling the high costs of goods. All the while, scammers are using AI technology to impersonate loved ones, their banks, or even their government. Too often, it ends up with people being duped. Every sheriff in my district tells a similar story. Police reports get filed. In some instances, hundreds of thousands of dollars are gone. Many of these hustlers are not even in our country. That is why I am reintroducing the QUIET Act. My bipartisan legislation would increase the penalties for any scammer who thinks that they can use AI to make an easy buck off of a senior citizen by stealing their Social Security check. Mr. Speaker, I encourage my colleagues on both sides of the aisle to stand up to these bad actors and join me in this fight.”
- 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
Defines Robocall and Text Message, as follows:
- Robocall: A call or text message made using equipment that dials stored numbers or generates numbers randomly/sequentially or uses an artificial/prerecorded voice.
- Text Message: Includes SMS, MMS, and RCS messages, but excludes real-time, two-way voice or video communications.
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.