This quarter has been marked by significant regulatory changes that compliance leaders need to be aware of to stay ahead in the ever-evolving landscape. Keep reading for a recap of the latest telemarketing legislation in Q2 of 2025. 

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. 

Courts Not Required to Follow FCC Rules in Telemarketing Lawsuits  

On June 20, 2025, the Supreme Court reconsidered the Ninth Circuit’s conclusion in McLaughlin Chiropractic Associates, Inc. v. McKesson Corp, making things a lot less predictable for companies making telemarketing calls or sending promotional texts. Up until now, if a business followed the Federal Communications Commission’s (FCC) rules or interpretations of the Telecommunications Consumer Protection Act (TCPA), they could usually expect some legal protection – even if a lawsuit was filed. Courts often looked to the FCC for guidance, and FCC decisions were treated as the final word. 

The recent Supreme Court decision explained that requiring judges to always follow the FCC would upset the balance between government branches, since interpreting laws is a core judicial responsibility. 

The Supreme Court’s decision alters the legal framework governing how courts address the TCPA in private litigation. The Court determined that the Hobbs Act, which gives appeals courts the power to review FCC rules before they are enforced, does not force trial courts to treat FCC guidance as binding in private lawsuits. Meaning, federal courts don’t have to accept a previously issued FCC interpretation on the same topic; as such, different courts in different parts of the country might disagree about what counts as a robocall, what kind of consent is needed, or what technology is allowed.  

• What’s allowed in one state might be illegal in another. 
• Businesses can’t lean solely on FCC rules as a defense. 
• There’s significantly more legal uncertainty for all parties. 

As a result, businesses should expect more variation and unpredictability in how TCPA lawsuits are decided. It is now especially important to keep careful records of consent and opt-outs, to stay up to date with new court decisions, and to be ready to adjust compliance programs quickly. Companies should continue to monitor both FCC updates and court rulings and be prepared for the possibility of renewed challenges to key FCC TCPA interpretations, since courts may now disagree with the FCC’s position in future cases. 

In summary, this decision shifts some of the authority for interpreting telemarketing law away from the FCC and back to the courts. Companies must now treat compliance as a moving target, shaped by both agency guidance and the independent decisions of judges across the country. 

New Texas Mini-TCPA Law Passed and Effective September 1, 2025 

Signed by the Governor on June 20th, Texas Bill SB140 (amending Tex. Bus. & Com. Code § 302.001 et seq.) transforms the scope of telemarketing regulation by expanding the types of communications covered by telemarketing rules, granting consumers powerful new legal rights and establishing some of the country’s toughest penalties for violations. Businesses reaching out to Texans via phone, text, or multimedia messages should brace for increased regulatory oversight and greater legal risk. 

Summary of new provisions: 

1. Broadens definitions for “Telephone Call” and “Telephone Solicitation” 
   • In addition to traditional voice calls, now explicitly includes text messages (SMS/MMS), image messages, and virtually any digital message intended to sell goods or services 
   • Telemarketing now includes not only voice calls, but also SMS, MMS, and virtually any digital message intended to sell goods or services 
2. Private Right of Action 
   • Introduced under the Texas Deceptive Trade Practices and Consumer Protection Act (DTPA) for violations of core telemarketing requirements (e.g. calling time restrictions, failing to honor opt outs, failure to register) 
   • Use of automatic dialing announcing device (ADAD, e.g., autodialers and robocall systems) is explicitly covered and enforceable under DTPA
   • “Consumers will be able to seek both economic damages and damages for mental anguish, significantly increasing potential exposure in litigation”
   • Consumers can sue for each violation with no limit on the number of lawsuits per consumer for repeated violations 
3. Increased Penalties/Unlimited Recovery 
   • Statutory damages range from $500 to $5,000 per violation, with potential for treble damages for knowing or intentional violations 
   • Consumers can bring repeated actions for ongoing or repeated violations, with no cap on recoveries 
4. Consumer Protections 
   • Businesses must obtain valid, documented consent for all forms of outreach and must provide reliable and prompt opt-out mechanisms 
   • More strict requirements for honoring opt-out requests, call time restrictions, and telemarketer registration 
5. Litigation Exposure 
   • Businesses face heightened risk of lawsuits, including class actions, for noncompliance 

SB140 signals a major change in Texas telemarketing law, with consequences that could impact any business targeting Texas consumers. With the law set to take effect on September 1, 2025, companies have limited time to assess and strengthen their compliance practices. The penalties for failing to comply are substantial, and the risk of litigation is poised to increase dramatically. Businesses should move quickly to implement thorough compliance measures in preparation for this new regulatory environment. 

Clarification: FCC’s Consent Revocation 10-day Timeline is in Effect  

When the FCC issued the TCPA Order on April 7, 2025, delaying certain telemarketing consent revocation rules, it was unclear if the FCC delayed all 47 CFR 64.1200(a)(10) or just the rules requiring businesses to apply opt-outs across all communication types.  

It’s still not exactly clear; no timeline (other than the delay) is mentioned in the Order. But the most popular published interpretations from the general legal community support the April 11, 2025, effective date honoring marketing consent revocation/op- outs within 10 days or sooner. Arguably, consent revocation applies immediately (no waiting period), so this delayed language just adds to the confusion.  

Regardless, be sure your consent revocation timeline can meet or exceed this 10-business-day requirement to be compliant. 

Gov. Abbott Signs TRAIGA (Texas Responsible Artificial Intelligence Governance Act) into Law 

On June 22nd, the Sunday night before the 2025 bill enactment deadline, TRAIGA (HB 149) was signed into law by the Texas Governor. The new law applies to those promoting, advertising, or doing business in Texas, producing products/services used in Texas, or developing or deploying AI in Texas. 

Proposed in December 2024 and modeled after Colorado and EU AI Acts, TRAIGA originally contained sweeping regulation of “high-risk” AI with substantial private sector requirements (e.g. consumer protection, impact assessments, disclosure). 

Since March 2025, the bill was scaled back with the most onerous private sector obligations removed or limited to government entities, and with a new focus on prohibited uses such as behavioral manipulation and deep fakes. It’s interesting timing, given Congress’ proposed AI moratorium in the budget reconciliation bill, approved by the House of Representatives but in the Senate “has been met with backlash by both policymakers and advocacy groups that have argued the federal government’s inaction on overseeing AI systems makes movement by the states all the more important.” 

TRAIGA does not specifically mention “AI-driven conversational compliance” or “artificial voices for telemarketing” by name, but the law’s broad definitions and prohibitions clearly encompass such technologies if they qualify as “AI systems” under the Act. 

Companies engaging in telemarketing practices should know that while TRAIGA does not specifically regulate artificial voices in telemarketing, it does prohibit the deceptive or manipulative use of AI. If artificial voices are used in a way that could mislead consumers, this could risk a TRAIGA violation. 

The effective date is January 1, 2026. 

2025 Year-to-Date TCPA Litigation Continues to Trend Upwards 

Through the first four months of 2025, the volume of telemarketing litigation has continued to rise, with class action lawsuits remaining the predominant form of legal action. 

A total of 880 Telephone Consumer Protection Act (TCPA) cases have been filed, marking a 46% increase compared to the 604 cases reported during the same period in 2024. 

 

The 691 class action cases filed between January and April 2025 are up 109% from the 331 class actions filed during the same timeframe last year. 

Class action cases averaged 79% of all TCPA filings, highlighting a continued trend toward collective action and the pursuit of increased negotiating leverage against major defendants. 

Even with the private right of action provision in TCPA, the dramatic surge toward class action litigation offers an additional advantage for class members by providing access to resources and legal expertise they might otherwise lack. By participating in a class action, members not only seek justice for their own grievances but also help deter future misconduct, benefiting both themselves and the wider public. 

As a company utilizing telemarketing (calls or texts), be vigilant about regulatory developments and how they impact your business – the last year has been all about ‘consent’, so be sure you are honoring it correctly, timely, and without fail. 

Source: Webrecon. 

States Push Forward with More Proposed Telemarketing Law Changes in April and May Crackdown

Across the country, state lawmakers are advancing a wave of new and revised telemarketing legislation – each designed to tighten restrictions, boost consumer protections, and hold businesses accountable for unsolicited calls, texts, and automated outreach. See below for the latest state level activity. 

Illinois HB 2435 – Amends Telephone Solicitations Act to ban telemarketing calls made with automatic dialing systems – unless the recipient has given explicit consent or has an established business relationship with the caller. Consent can be revoked at any time using the same method it was given. The law also prevents the transfer or sale of consent to third parties and introduces a private right of action, allowing affected individuals to seek $500 in statutory damages plus legal costs and attorney fees.  

• Status: Passed House; awaiting final Senate action.  

North Carolina HB 520 – Tightens stance against deceptive caller ID practices by increasing penalties for misrepresenting or blocking caller ID information, granting victims the right to sue (private right of action) and setting a civil penalty at $10,000 per violation. 

• Status: Passed House, awaiting final Senate action. 
• If enacted, effective December 1, 2025. 

North Carolina HB 936 – Amends telemarketing law to prohibit “robocalls,” defined as a voice communication that uses artificial, computer-generated, or pre-recorded voice messages, including soundboard calls and ringless voicemails, without “prior express written consent.” 

• Status: Passed House, awaiting final Senate action.  

Oregon HB 3865 – Expands definition of “automatic dialing and announcing device” to include text messages; adds “telephone solicitation” definition and applies related obligations; requires (i) a method for the recipient to indicate they do want to receive future calls, (ii) caller name and purpose to be disclosed within first 10 seconds of call or in the initial text; restricts use of an ADAD outside of 9 a.m. to 7 p.m.; and prohibits more than 3 telephone solicitations in a 24-hour period.  

• Status: Passed House, referred to Senate Rules Committee. 

Massachusetts HB 3940 – Targets the practice of “spoofing” local numbers by prohibiting telemarketers from making or causing to be made an unsolicited telephonic sales call to a consumer using local phone numbers or area codes that are not linked to their physical location or place of business in Massachusetts.  

• Status: Introduced (4/3/2025) 

New York SB 6461 – Requires telemarketers to add a customer’s phone number to all do-not-call lists if the customer requests to be added to any one of them.  

• Status: Introduced (3/14/2025), pending Senate. 

New York AB 6853 – Bans unsolicited telemarketing sales calls during declared states of emergency, but only if the emergency declaration specifically states that such calls would interfere with emergency response efforts. The ban would last for two weeks at a time, with extensions possible if new findings of necessity are made.  

• Status: Introduced (3/25/2025) 

FCC’s One-to-One Consent Rule: A Final Update (we think) 

Even after the 11th Circuit Court of Appeals “stayed” this Federal Communications Commission (FCC) One-to-One Consent ruling just hours before the January 27, 2025, effective date, the restlessness around the 11th Circuit Court of Appeals’ stay gently graduated from a buzz to an uproar, with a coalition supporting a laser-focused resuscitation of this regulation. 

As outlined in our March 2025 regulatory report reflecting bilateral activity supporting and opposing this FCC rule (with the majority of activity leaning heavily in favor of the rule), it appeared that the possibility of a rule resuscitation could have legs. The National Consumer League (NCL) also filed a petition for rehearing en banc, tenaciously pursuing a chance to intervene. 

But then the first shoe dropped. 

On April 4, 2025, the FCC issued an Opposition to Motion to Intervene, summarizing the government’s decision to forego further review of the 11th Circuit’s ruling and stating its stance against allowing Proposed Intervenors to pursue further litigation. 

So that announcement settled in… 

And the second shoe dropped. 

On April 22, 2025, the 11th Circuit Court released an Order stating, “After careful review, the Court denies the motions to intervene.” This effectively puts an end to any attempt by NCL and others to revive the One-to-One regulation, barring a Supreme Court review, which appears highly improbable. 

For all intents and purposes in the telemarketing world, the FCC’s one-to-one consent rule is dead. However, given the craziness of the last year in the telemarketing space, no bets are off the table — so stay alert. 

Long-Known Robocall Scammer Permanently Banned from Industry Through Joint State and Federal Collaboration  

John Spiller and his various companies—such as Rising Eagle Capital Group LLC, Rising Eagle Capital Group–Cayman, and JSquared Telecom LLC—have long been a focus of FCC attention. Following the detection and reporting of suspicious activity in 2018, an investigation singled out Spiller and his associates as responsible for nearly a billion robocalls, prompting the FCC to propose a then-record $225 million fine.  

This officially imposed federal enforcement action was issued due to violations of the Telephone Consumer Protection Act (TCPA) and the Truth in Caller ID Act.  

The robocalls targeted consumers on the Federal Do Not Call list, using false caller ID information, misrepresenting well-known health insurance providers, with intent to deceive recipients.  

Even after the multi-million dollar fine, Spiller continued to operate under separate alias’s (in multiple states) launching new VoIP providers, violating a 2023 court order and barring him from participating in any business in the telecom industry.   

Just days ago, a coalition of state attorneys general secured a district court ruling against Spiller to pay more than $600,000 in attorney fees and costs to eight states and permanently bar Spiller from operating in the telecommunications industry.  

The coalition of attorneys general included Arkansas, Indiana, Missouri, Michigan, North Carolina, North Dakota, Ohio, and Texas.   

Ohio Attorney General Dave Yost said “this scammer’s line is dead — and it’s not coming back.”   

Timeline of Key Events:  

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. 

EAI Seeks Waiver for Texting During TCPA “Quiet Hours” Amidst Upsurge in Litigation  

On March 3, 2025, the Ecommerce Innovation Alliance (EAI) and others filed a petition with the Federal Communications Commission (FCC) seeking a declaratory ruling for the following:  

• To address the torrent of frivolous litigation exploiting the Telephone Consumer Protection Act (TCPA)  
• “To confirm Individuals who provide prior express written consent to receive text messages cannot claim damages under the TCPA for messages received outside the hours of 8 a.m. to 9 p.m.”  
• To request clarification or waiver of 47 C.F.R. § 64.1200(c)(1) regarding telephone solicitations sent to wireless devices without prior express written consent  

The primary argument in the EAI petition challenges the current FCC rules imposing an unworkable standard for businesses to know the “called party’s location” when messages are delivered to mobile phones, especially given the FCC’s restriction on access to location data, negating the businesses’ ability to comply with the Quiet Hours provision.  

The EAI affirms that the only remedy currently available for consumers disturbed by the timing of messages is to revoke consent.  

Petitioners suggest two options:  

1. Waiving 47 C.F.R. § 64.1200(c)(1) for telephone solicitations to wireless phones  
2. Creating a non-rebuttable presumption that a wireless phone’s NPA-NXX (area code/exchange) is the called party’s location 

Further, petitioners state granting the petition would curb abusive TCPA litigation, protect legitimate businesses, and allow companies to focus on innovation, job creation, and better services for consumers.  

On March 11, 2025, the FCC responded to this EAI petition and issued this Public Notice Seeking Comment (comment date: April 10, 2025, reply date: April 25, 2025).  

Here is a sampling of cases filed in 2025 for texting outside of TCPA Quiet Hours:  

• Amani Manning v. Sol de Janeiro USA, Inc    
• Valeria Torres vs Steve Madden   
• Savage v. Skinny Fit, LLC   
• Toscano v. Grenades, LLC   
• Hensley v. Regal Cinemas, Inc.   
• Vallejo v. R. J. Reynolds Tobacco Company   
• Melissa Gillum v. Good American, LLC    
• Laureta v. Dave & Buster’s Inc   
• James v. Disney DTC LLC   
• Smith v. XYZ Corp   
• Doe v. ABC Inc   
• Johnson v. Marketing Solutions LLC   
• Brown v. Telecom Services   
• Williams v. Digital Outreach 

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  

 

In a declaratory ruling issued by the Federal Communications Commission (FCC) on June 9, 2025, the EEI petition was granted and the FCC confirmed demand response communication “calls and texts are “closely related” to the utility service.”    

This means “when a consumer gives a utility their phone number, they give their prior express consent to receive non-telemarketing demand response calls and texts.”  

This is a huge win for utility companies, who claim this action benefits consumers through enhanced grid reliability, cost savings, and by supporting newer technologies.  

In strong opposition to the EEI petition, the National Consumer Law Center (NCLC) argued that implied consent was not enough and would reduce consumer control over unwanted calls and texts. 

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 . 

Former Credit Card Processing CEO Gets 7 Years in Prison for Telemarketing Scam  

On March 31, 2025, Brandon Becker of Los Angeles, received a 7-year prison sentence by U.S. District Judge Loretta A. Preska (which was lower than the Prosecutors 9-year request, per sentencing guidelines), for a telemarketing scheme leading 19,000 people to losses of $19 million.   

“This is a very serious offense that caused a great deal of harm to a great number of people,” the judge said.  

Judge Preska also directed Becker to make $1.9 million in restitution, forfeit $11.4 million, and surrender to custody on May 30th.  

In 2012, partnering with E.M. Systems & Services LLC and owner Steven Short, this debt relief company based in Florida started offering credit counseling services to low-income consumers, often charging fees over $1,000.   

Becker had a chance to shut down the scheme in 2015 and was urged to do so by an associate amidst a Federal Trade Commission (FTC) lawsuit, but instead made the decision to not only continue operations but to further grow and develop the farse.  

Steven Breier, a former sales agent at Becker’s company, will be sentenced in May.  

Case 1:19-cr-00704, U.S. District Court for the Southern District of New York. 

Proposed Senate Bill Gives FCC Power to Collect TCPA Fines  

Senate Bill 1025 (S.1025) (also known as the FCC Legal Enforcement Act) introduced on March 13, 2025, by Sponsor Senator Ben Ray Lujan (New Mexico), authorizes the Federal Communications Commission (FCC) “to enforce its own forfeiture penalties with respect to violations of restrictions on the use of telephone equipment, and for other purposes.”  

The FCC Legal Enforcement Act, described as “necessary in the judgment of the Commission to protect subscribers from unwanted calls,” amends several sections of Title V of the Communications Act of 1934, asserting that this enhancement of the FCC’s power:  

• Strengthens consumer protection from unlawful practices involving telephone equipment  
• Streamlines enforcement of the penalty process imposing penalties on violators, ensuring faster and more efficient enforcement  
• Promotes adherence to existing restrictions on telephone equipment by increasing the consequences for violations  

The bill was read twice and referred to the Committee on Commerce, Science and Transportation.  

FCC 8th Call Blocking Order Deadline for Terminating Carriers Published  

Per the new Federal Communications Commission (FCC) Report & Order (R&O), two new rules go into effect within the next year for Voice Service Providers (VSPs):  

1. Use a reasonable Do-Not-Originate (DNO) list to block suspicious traffic (new for VSPs, already in effect for gateway and messaging service providers)  
   • Will be effective 90 days after publication in the Federal Register (no effective date yet)  
   • DNO list scope remains undefined but suggests could include “only invalid, unallocated, and unused numbers, as well as numbers for which the subscriber has requested blocking”  
   • During an investigation, VSPs may be required to provide a copy of the DNO list to the Enforcement Bureau  
2. For analytics based blocked calls, use Session Initial Protocol (SIP) code 603+   
   • Effective Date: March 24, 2026 
   • Includes all terminating carriers using analytics-based call blocking (blocked by 3rd party services or by themselves); must implement SIP code 603+ (or ISUP code 21 for non-IP networks) for response notifications, replacing certain existing SIP codes  
   • 607 remains indicating the call was blocked at the subscriber’s direction without the use of analytics 

FCC Commissioner Geoffrey Starks Resigns   

On March 18, 2025, Commissioner Starks “sent a letter to the President and Leader Schumer indicating that I intended to resign my seat as a Commissioner this Spring.” Specific timeframe is undetermined.   

See Commissioner Starks’ statement here.   

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.” 

After FCC Commissioners Starks and Simington Departure, Two Commissioners Remain  

In a June 4th statement, Commissioner Nathan A. Simington announced his tenure would end on Friday, June 6, 2025. He noted he remains “committed to advancing the cause of limited government, free speech, and American innovation. These principles guided my time at the Commission and will continue to shape my future endeavors.”  

After his March 18 announcement stating his plans to leave the Commission, Commissioner Geoffrey Starks issued a formal statement on June 4, declaring his last day as June 6, 2025, expressing “serving as Commissioner has been the highlight of my career.”  

The two remaining Commissioners include Chair Brendan Carr and “Democratic member, Anna Gomez, appointed by President Joe Biden.” A three-member quorum is required for business needing commission votes, “although some decisions can be made at the staff level, overseen by Carr.”  

Senate Republican Olivia Trusty has been named, but her confirmation is pending in the Senate. 

Olivia Trusty Confirmed by Senate as New FCC Commissioner 

On June 17, a short time after Commissioners Simington and Starks officially exited on June 6, Senate Republican Olivia Trusty was confirmed by the Senate to the Federal Communications Commission (FCC). Trusty was confirmed in time for the FCC’s June 26 meeting, ensuring the board has a quorum and provides Republicans with the 2-1 majority. 

FCC Chairman Brendan Carr issued the following statement: 

“I want to extend my congratulations to Olivia Trusty on her confirmation to serve as an FCC Commissioner after President Trump’s nomination earlier this year. Olivia will be a great addition to the Commission. Olivia brings years of valuable experience to the agency, including her public service on Capitol Hill and time in the private sector. I am confident that her deep expertise and knowledge will enable her to hit the ground running, and she will be an exceptionally effective FCC Commissioner. I look forward to welcoming Olivia to the Commission as a colleague and advancing an agenda that will deliver great results for the American people.” 

Commissioner Anna M. Gomez added: “I look forward to working with her to return the FCC to its core priorities of protecting consumers, promoting innovation and competition, and securing our communication networks.” 

Sorenson’s QUIET Act Gains New Sponsors 

In the last three months, the QUIET Act has gained the following sponsors: 

• Zachary Nunn (IA) 
• Thomas R. Suozzi (NY) 
• Sarah McBride (DE) 
• Melanie A. Stansbury (D-NM-1) 
• Kristen McDonald Rivet (D-MI-8) 
• Rep. Ted Lieu  [D-CA-36] 
• Rep. Jefferson Van Drew (R-NJ-2) 

FCC Seeks Comment on Negotiation-Based Process to Transition Entire 10 Mhz in the 900 Mhz Band for Broadband Use  

On March 17, 2025, the Federal Communications Commission (FCC) proposed a review of rules governing 896-901/935-940 MHz band, for use in counties where applicants and licensees reach private agreements.  

The review includes evaluating whether the current 900 MHz broadband rules, such as eligibility criteria, application requirements, licensing and operating rules, and technical requirements, are appropriate for a ten-megahertz broadband licensing framework.   

The FCC has delegated authority to the Wireless Telecommunications Bureau to modify or terminate the current freeze on certain applications in the 900 MHz band.  

Comments Due: May 16, 2025  

Reply Comments Due: June 16, 2025 

New Area Codes for Canada 

The NANPA (North American Number Plan Administrator) has announced the implementation of new area codes: 

• New Area Code: 942  
  • Jurisdiction: Ontario, Canada  
  • Effective Date: April 26, 2025  
  • Type: General Purpose  
  • Overlay: 942 overlays 416/437/647 
• 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

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