Below is a recap of essential regulatory updates for contact compliance professionals for the month of May.
This is a marketing blog and not intended nor should be interpreted as legal advice. Please seek legal counsel for full interpretations of all rules and laws outlined in this blog.
June Holiday Solicitation Bans
Please be aware of the following U.S. holiday telephone solicitation bans for June 2025:
- On June 2, 2025, Alabama prohibits unsolicited marketing calls to residents in observance of Jefferson Davis’s birthday.
- On June 14, 2025, Pennsylvania prohibits unsolicited marketing calls to residents in observance of Flag Day.
- On June 16, 2025, Utah prohibits unsolicited marketing calls to residents in observance of Juneteenth Day.
- On June 19, 2025, Alabama*, Louisiana, Nebraska**, Pennsylvania, and Rhode Island prohibit unsolicited marketing calls to residents in observance of Juneteenth Day.
Other holidays may be proclaimed by the Governor in each state throughout the year.
*The Governor of Alabama recently signed into law HB 165 which declares Juneteenth a state holiday on June 19th of each year, effective June 1.
**Nebraska does not prohibit calls on Sundays or legal holidays; however, it does restrict the use of prerecorded messages from 1 pm to 9 pm on these days (subject to certain exceptions).
Please be aware of the following Canadian holiday telephone solicitation bans for June 2025:
- On June 21, 2025, Northwest Territories and Yukon prohibit unsolicited sales and marketing calls in observance of National Indigenous Peoples Day.
- On June 23, 2025, Newfoundland and Labrador prohibit unsolicited marketing calls in observance of June Day (previously Discovery Day).
- On June 24, 2025, Quebec prohibits unsolicited marketing calls in observance of St. Jean Baptiste Day.
Alabama Governor Signs Bill into Law: Juneteenth is an Official State Holiday
On May 8, 2025, Governor Kay Ivey of Alabama signed AL HB165 into law, officially establishing Juneteenth as a state holiday on June 19th of each year, which prohibits telephone solicitations to consumers in Alabama on that date.
Recognized as a federal holiday since 2021, this new Juneteenth Alabama law is effective on June 1, 2025.
Click here for more information.
FCC’s New Move Against Robocalls Closes the Non-IP Network Loophole
The Federal Communications Commission (FCC) has advanced its efforts to curb illegal robocalls by addressing a loophole in non-IP networks, allowing robocallers to bypass authentication measures that safeguard consumers.
Robocalls continue to plague consumers, costing the economy millions annually through fraud and wasted time. The STIR/SHAKEN framework, which verifies caller IDs, has been effective but fails on non-IP networks, leaving a vulnerability that scammers exploit.
The 2019 TRACED Act mandates STIR/SHAKEN for IP networks and a solution for non-IP networks. While most providers have adopted STIR/SHAKEN, non-IP networks remain weak. The new rules aim to close this gap, providing a more robust defense against fraudulent calls, such as:
- The FCC recommends that voice service providers using non-IP technology adopt caller ID authentication frameworks to ensure calls can be verified even on older networks
- Providers would have two years to comply if the proposal is approved
- Regular compliance certification would be required
Paul Benda from the American Bankers Association praised the FCC’s proposal, emphasizing the importance of protecting consumers from fraudulent calls that impersonate legitimate businesses.
The FCC’s Notice of Proposed Rulemaking (NPRM) adopted on April 28, “seeks to establish criteria for evaluating whether frameworks meet the TRACED Act standards, and it posits that two existing frameworks meet those standards while taking further comment on a third.”
The FCC is seeking public comments on the proposal, with a final decision expected soon. If adopted, the new rules would require compliance within two years, significantly changing how non-IP networks handle call authentication.
See the FCC Fact Sheet for more information.
New York State of Emergency Extended Through June 8, 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 47.5, declaring a State Disaster Emergency in the State of New York arising from an illegal and unlawful strike by correction officers, was extended through June 8, 2025.
Gryphon has extended State of Emergency blocks for New York to June 8, 2025, to ensure compliance with the above Executive Orders.
US QUIET Act (H.R. 1027) Gains Three More Sponsors
The Quashing Unwanted and Interruptive Electronic Telecommunications Act (“QUIET Act”) has gained three additional co-sponsors:
- 04/28/2025: Rep. Melanie A. Stansbury (D-NM-1)
- 05/07/2025: Rep. Kristen McDonald Rivet (D-MI-8)
- 05/20/2025: Rep. Ted Lieu [D-CA-36]
This bill, proposing disclosure of Artificial Intelligence (AI) use at the beginning of a telemarketing call, along with increased penalties for violations involving AI voice or text messages, now has 14 co-sponsors plus original co-sponsor Sorensen (IL), for a total support of 15.
March 2025 YouMail Robocall Index Report: Robocall Volume is Still Problematic
YouMail released it’s monthly Robocall Index Report, which includes data on robocalls in the United States based on extrapolating from the robocall traffic attempting to get through to YouMail’s millions of active users.
Key findings:
- 4.8 billion robocalls in March is a 7.9% increase over February, and a 12.7% increase year-over-year from March 2024
- The most problematic robocall campaign in March targeted people to switch to high-deductible medical plans
- 54% are scams and telemarketing calls
- Scam calls have decreased, but robocalls are still on the rise
March 2025 U.S. Robocall Breakdown
Regulatory Compliance in the First 100 Days
On April 29, 2025, FCC Chairman Brendan Carr’s office published Wins Delivered During First 100 Days, expressing “thanks and appreciation to the agency’s talented staff for the great and efficient results that they have already delivered,” along with highlights in key areas of impact, including consumer protection.
The document states:
“Protecting Consumers:
- Expanded the FCC’s work to combat illegal and annoying robocalls by adopting rules that strengthen the agency’s call blocking rules using reasonable do-not-originate lists.
- Proposed a new framework that would ensure caller ID authentication solutions are extended to calls transmitted over non-IP networks, where a gap persists today.
- Launched enforcement activities to protect Americans from robocall offenders and other bad actors in the call path.
- Proposed rules to ensure consumers are not inundated by excessively loud commercials.
- Released a Public Notice seeking comment on privacy issues related to Text-to-988.”
By contrast, the State Attorney General’s shaped the regulatory dynamic in the first 100 days as well, covering broader regulatory reforms targeting various sectors, including investments, environmental protection, transportation, energy, and healthcare.
Specifically for investments, Democratic AGs filed an amicus brief opposing the administration’s move to effectively shutter the Consumer Financial Protection Bureau, aiming to preserve consumer protection in financial matters.
“If the first 100 days of the second Trump administration is any indication of what is to come, attorneys general will likely continue to play a key role, with Democratic and Republican attorney general involvement manifesting in drastically different ways.”
Broader regulatory reforms anticipated by the administration will affect outbound communications regarding compliance and regulatory updates across various industries.
Email Contact with Debtors During Quiet Hours is Now OK in Florida
In response to the rise in class actions on this subject, in addition to legislative acknowledgement that the Florida Statute “was adopted before e-mail communication became commonly used and that the only specific communication explicitly contemplated in such subsection is telephone calls,” the Florida Consumer Collections Practices Act (FCCPA) was modified to remove e-mail as prohibited practice.
On May 16, 2025, Florida “Debt Collection” Senate Bill 232 (SB 232) was signed into law by the Governor and is now officially Chapter No. 2025-23.
A November 2024 Court Decision (Quinn-Davis v. TrueAccord Corp., No. 1:23-CV-23590, 2024 WL 4851344) found that the “time the consumer opened the email” would identify the moment when the creditor communicated with the debtor. However, the business community quickly realized an email “opened” during quiet hours could still have an actionable case. So, to clarify this ambiguity, SB232 was born.
Overview of SB 232 (2025)
- Sponsor: Sen. Ana Maria Rodriguez
- Key Provisions:
- Revises prohibited practices for individuals or entities attempting to collect consumer debt.
- Enhances consumer protections and enforcement mechanisms, especially against out-of-state debt collectors.
- Clarifies civil remedies, administrative duties, and penalties for violations.
Specifically related to e-mail, 559.72 prohibited practices generally. In collecting consumer debts, a person may not:
“(17) Communicate with the debtor between the hours of 9 p.m. and 8 a.m. in the debtor’s time zone without the prior consent of the debtor. This subsection does not apply to an e-mail communication that is sent to an e-mail address and that otherwise complies with this section.”
Legislative Timeline:
- Introduced: January 14, 2025
- Senate Passed: April 16, 2025 (YEAS 36, NAYS 0)
- House Passed: April 29, 2025 (YEAS 116, NAYS 0)
- Signed by Governor: May 16, 2025
- Effective Date: May 16, 2025
You can read the full bill text and history on the Florida Senate website .
NCLC Offers Strong Opinions on TCPA Challenges: EAI and EEI Petitions to the FCC
The National Consumer Law Center (NCLC) is known for being vocal about its passion projects. After the 11th Circuit Court of Appeals “stayed” the FCC’s one-to-one consent rule in January, the NCLC’s opposition to abandoning the rule was public, supported, and steadfast. Even though their intended outcome didn’t prevail, they were heard.
The NCLC continues to project its opinion on various Telephone Consumer Protection Act (TCPA) challenges. Recently, the NCLC openly opposed the following petitions to the FCC, in partnership with several other consumer organizations.
Ecommerce Innovation Alliance (EIA)
The EIA is seeking FCC changes to how the TCPA is interpreted and enforced, specifically regarding “quiet hours” for telemarketing calls and texts:
- EIA requests the FCC clarify how to determine the “local time at the called party’s location” for TCPA Quiet Hours compliance.
- Specifically, EIA proposes a non-rebuttable presumption that the area code of a mobile number reflects the user’s time zone.
- This will protect telemarketers from liability if they send messages during quiet hours based on the area code, even if the recipient has moved to a different time zone.
NCLC’s position:
- NCLC and consumer groups oppose the EIA’s request to change or waive FCC rules on telemarketing “quiet hours.”
- The current FCC rules are clear and effective; restating them would cause confusion.
- Courts, not the FCC, should decide disputes about telemarketing violations.
- Using area codes to determine time zones would lead to more unwanted late-night calls.
- A waiver of quiet hours would undermine consumer protections and increase robocalls.
- NCLC urges the FCC to deny the petition and support the development of better tools to help telemarketers comply with existing rules.
Edison Electric Institute (EEI)
EEI is seeking an FCC ruling under the TCPA to allow automated calls and texts promoting enrollment in demand response programs without requiring explicit prior express consent from utility customers:
- EEI requests the FCC confirm that demand response communications are “closely related” to utility service, allowing utilities to send such messages under the TCPA based on implied consent (i.e., when a customer provides their phone number) —without requiring additional consent.
- EEI argues that these communications are essential for grid reliability and cost management, helping customers reduce energy use during peak times and avoid higher utility bills.
- EEI seeks to resolve confusion from a 2016 FCC ruling, which they say has discouraged utilities from using demand response messaging due to uncertainty about TCPA compliance.
- Oracle Utilities issued an Ex Parte supporting EEI’s position, sharing how negligible opt-out rates are for these types of messages, then stating, “customers do not view opt-out demand response communications as intrusive or unwelcome” and instead, have a “positive effect on customer satisfaction.”
NCLC’s position:
- Opposes EEI’s request to treat marketing messages for demand response programs as part of standard utility service.
- Argues that explicit prior express consent is required for such messages and that simply providing a phone number for service is not enough.
- Warns that loosening consent rules would reduce consumer control over unwanted calls and texts.
- Suggests these messages could be allowed under a narrow FCC exemption, not by weakening existing protections.
- Emphasizes that optional programs like demand response are not essential utility communications and should be treated differently.
The FCC offered comment periods for both EIA and EEI petitions, which closed on April 25, 2025. Petitions, public comments, and reply comments are in review with the FCC’s Consumer and Governmental Affairs Bureau.
Key Issues and Organizational Positions on TCPA Petitions
New Area Code Implementation for Canada
The North American Number Plan Administrator (NANPA) has announced the implementation of a new area code in Canada:
- New Area Code: 257
- Jurisdiction: British Columbia, Canada
- Effective Date: May 24, 2025
- Type: General Purpose
- Overlay: 257 overlays 236/250/257/604/672/778
Gryphon has implemented this new area code throughout all systems, ensuring compliance as of the published effective date.
For more information, see this planning letter.
FCC Chairman Carr Announces a Changing of the Guard for New Wireline Chief
On April 29, 2025, Joseph Calascione was appointed Chief of the Wireline Bureau in a public statement. Chairman Carr shared the following statement on the appointment:
“I’m pleased that Joseph has agreed to return to the FCC to lead the Wireline Bureau. His deep legal and policy expertise in wireline and broader communications issues will be instrumental in helping the Commission modernize its regulatory approach, expand economic opportunities, and deliver meaningful results for the American people.”
On April 28, 2025, FCC Chairman Brendan Carr extended his appreciation to Trent Hardrader for his leadership of the Wireline Bureau during a key transitional period, following a distinguished tenure in various roles across the agency:
“I’ve had the privilege of working closely with Trent on a wide array of critical FCC initiatives over the years. He is a true problem solver—consistently tackling some of the agency’s most challenging and complex issues with skill and dedication. His deep institutional knowledge, built over years of service, has made him an invaluable asset. Trent has always been a trusted colleague and a committed public servant. I’m grateful he accepted my request to lead the Wireline Bureau during this transition, and as he steps away from that role, I look forward to the continued impact of his work.”
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 AI can help you manage these updates, reach out to us today.