Week ending September 25, 2026

The Commission votes Wednesday on the TCPA consent-revocation rewrite. The banks and a messaging aggregator asked for the same one-word fix to the circulated draft, and the utilities and the aggregator split on its central change. Keelin Ferris in the Chairman’s office took meetings on that item, on toll-free and numbering administration, and on rural high-cost support within two days of each other. The FTC opened an advance notice on whether platforms that optimize scam ads should answer for impersonation fraud.

The revocation draft: one shared edit, one split

The Sunshine notice released September 23 confirms the September 30 agenda: a Report and Order and FNPRM in CG 02-278 on consent revocation, and the 911 Framework NOI in PS 26-197.

Jonathan Thessin of the American Bankers Association met Ferris virtually on September 21 and by phone on September 22, and filed on September 23. ABA supports letting a caller treat a revocation sent in reply to an informational message as covering only that category. Its problem is the draft text for exclusive text-message revocation, which lets a sender designate replying with “any of the following standardized words” — stop, quit, end, revoke, opt out, cancel, unsubscribe. ABA reads that as possibly requiring all seven words in every message and asks the Commission to insert “one.” It also wants the follow-up clarification text allowed “within a reasonable time not to exceed the end of the next business day,” instead of the 2024 Order’s five minutes, or at least put out for comment in the FNPRM. Banks, it says, may send no follow-up at all under the current window because of the lawsuit risk of missing it.

ABA then brought seven other trades — ACA International, AFSA, America’s Credit Unions, the Consumer Bankers Association, the Defense Credit Union Council, the Electronic Transactions Association and the Student Loan Servicing Alliance — onto a joint letter to all three commissioners asking for the same two edits. The letter also backs the draft’s change to the 2015 fraud-alert exemption, which lets a bank reach a wireless number “obtained from a reliable source” rather than only one the customer provided — a number “supplied by a spouse or other family member who is authorized to be on the account; obtained when the customer calls the financial institution; or included in records obtained from another financial institution.” The trades say the provided-number condition is the main reason few banks use the exemption.

Vibes Media, through Jennifer Bagg and Alex Tate of HWG, filed on September 22 with the arithmetic for the keyword problem: “Because SMS are limited to 160 characters, however, and these words alone constitute 47 characters, senders of text messages will have to increase the number of messages they send.” Its exhibit turns one 160-character retail promotion into three segments. Vibes proposes one designated keyword disclosed before opt-in, in the first message and monthly after that.

The split is on categories. The Edison Electric Institute wrote on September 22 that utilities “have long been concerned that a customer seeking to stop one category of communications could inadvertently lose access to outage notifications, restoration updates, emergency communications, and other important service-related information,” and supports the category-scoped rule for that reason. Vibes, a messaging aggregator, says the same rule is harder to build than revoke-all: an opt-out rule that treats informational and marketing content differently across numbers, channels, business lines and vendors “is extremely burdensome for senders to operationalize—even more burdensome than a rule requiring an opt-out request to be applied to all types of messages.” Its alternative is to apply a texted opt-out “at the code level,” to the short code, ten-digit long code or toll-free number it was sent to, and failing that to push the effective date to twelve months after Federal Register publication.

Numbering, high-cost support and copper in the all-IP record

Somos met Ferris on September 22 — Ann Berkowitz and Joel Bernstein with Aaron Panner of Kellogg Hansen — and filed on September 24 across seven dockets, including WC 25-304, WC 25-208 and WC 20-174. The first half repeated Somos’s opposition to iconectiv’s petition for competitive bidding of the Toll-Free Numbering Administrator role, which Somos calls “both substantively unwarranted and procedurally defective.” The second half is about the IP transition: the Commission “should ensure that the systems for assigning and routing 10-digit telephone numbers are updated, so that legacy systems such as the NPAC and the LERG do not obstruct or undermine any of the benefits of network modernization,” with the Toll-Free Number Registry, which “consolidates assignment, routing, and portability,” offered as the model. Somos is the toll-free administrator; its RM-12012 rulemaking petition on numbering administration is in the caption. The letter runs two pages and does not describe the mechanism.

WTA’s Stephen Goodman brought four member companies — PMT, CTC, Farmers Mutual and Direct Communications — to Ferris in person the same day and filed in WC 26-96, the high-cost-for-an-all-IP-future proceeding. WTA walked through rural support mechanisms back to the 1934 Act and asked that high-cost support, access charges, subscriber line charges and CAF-HCL, now spread across separate proceedings, be addressed “holistically.” On LEO it said “the shared capacity (both intra- and inter-system) and asymmetric speeds make it unsuitable for critical rural applications such as precision agriculture, telehealth, remote education and AI services.” Premier Communications, with NTCA and JSI, met Associate Bureau Chief AJ Burton and WCB staff on September 17 about its Heartland service area in Iowa, which has received no ongoing high-cost support for most of the area since 2021; Premier asked that Heartland’s history not exclude it from whatever mechanism comes out of the proceeding.

In WC 25-209, the network-change docket, a Verizon customer in Christiansburg, Virginia wrote on September 24 that her copper landline is being discontinued with no cell coverage, fiber or broadband available, and satellite unreliable in bad weather: “I will no longer have access to 911 emergency services at all times.” Nineteen express comments from individuals landed in the same docket after September 18.

911: a functional scope test, and a warning about outage notices

Mark Fletcher, filing in a personal capacity, commented in PS 26-197 on September 24 on the circulated draft, before the NOI is voted. He asks the Commission to drop the 2003 four-factor scope test — real-time two-way voice, PSTN interconnection, competition with traditional service, E911 feasibility — for a functional trigger: “whether an entity, service, device, platform, or facility enables, represents, controls, or materially supports a request for emergency assistance or an essential element of its delivery.” He cites the Commission’s figure that 71.3 percent of 911 calls reported for 2024 came from wireless phones, and NTIA’s estimate of $5.802 billion to $9.277 billion still needed to finish NG911. The retirement section sets eight conditions before a legacy 911 element comes out, including end-to-end testing of routing, location, recontact and accessibility, and a diversity analysis for shared points of failure. On legacy facilities he writes: “This is not a request to disconnect necessary systems on an arbitrary date. It is a request to stop treating indefinite parallel operation as the safest default.” On enterprise systems he says cloud communications “separated telephone identity from physical place,” and cites Kari’s Law and RAY BAUM’S Act as the model for assigning dispatchable-location duties to whoever controls the information.

PSHSB released DA 26-1033 on September 25, reminding wireline, wireless, interconnected VoIP, cable, satellite, covered 911 and covered 988 providers of the special-facility outage notification rules. “Public safety organizations have made us aware of many examples of providers sending vague, inaccurate, or unnecessary notifications.” The notice restates the 30-minute deadline from discovery, attributes a third-party transport provider’s discovery of an outage to the provider, applies the duty to resellers that “lease or otherwise utilize” facilities, and lists the ten data elements a notice must carry. It notes that entities newly designated as covered 911 service providers under June’s FCC 26-39 are not subject to the notification requirement. PSHSB asks for “better notifications, rather than more notifications that confuse or mislead public safety officials about outages.”

Authentication: Pinger reaches Gomez’s office, and a media-plane pitch for the RMD

Pinger CEO Greg Woock, with Larry Fleischer, Matt Burgoon and Cooley’s Ron Del Sesto and Robert McDowell, met Edyael Casaperalta and Jonathan Uriarte of Commissioner Gomez’s office on September 16 and filed on September 18 across eight dockets. The asks match its September 11 filing: define “facilities” before attestation eligibility and self-classification attach to it, let the attestation decision follow the provider that serves the end user, and build traceback notification that reaches the responsible provider. The deck also makes an enforcement point from the RMD FNPRM itself — that the record suggests “the universe of bad-actor providers appears identifiable,” citing ZipDX’s analysis — and argues removal from the database already ends such a provider’s business.

Box Commons, a Wyoming 501(c)(6) that certifies audio data for AI systems, commented on the RMD FNPRM on September 24. Its argument is that STIR/SHAKEN and the RMD cover the signaling plane only: “A call that is fully authenticated under STIR/SHAKEN, properly signed with an A-level attestation, can still deliver audio that is entirely AI-generated, cloned, or manipulated.” It proposes that providers list content-provenance mechanisms in their mitigation plans, that the Commission open a proceeding on content-provenance metadata built on the PASSporT extension model and aligned with C2PA, and that “Content Provenance Authorities” certify provider practices alongside the STI-GA/STI-PA chain. The worked example is a PASSporT claim carrying ai_voice: true tied to a C2PA manifest, offered as evidence for the AI-voice disclosure rules proposed in FCC 24-84. The proof of concept it cites is a 22-station broadcast radio pipeline.

Comments on the RMD FNPRM are due October 9, replies November 9.

FTC asks whether platforms should answer for impersonation ads

The FTC announced on September 24 an ANPRM on whether to amend the Impersonation Rule, write a separate rule, or act without regulation to address ad-optimization tools that social media, search and marketplace platforms sell to advertisers, including scammers posing as businesses and agencies. The notice asks about advertiser vetting, ad monitoring, investigation and takedown of suspected impersonation ads, and discipline of offending advertisers. The Commission cites more than one million imposter reports in 2025 with nearly $3.5 billion in reported losses, and says nearly 30 percent of consumers who lost money that year were first contacted on social media, with $2.1 billion lost. The vote was 2-0. Comments are due 60 days after Federal Register publication.

Honorable mentions

The Enterprise Communications Advocacy Coalition, through Mitchell Roth of Roth Jackson, objected on September 25 to dismissal of its July 30, 2021 petition asking the Commission to declare the Florida Telephone Solicitation Act preempted as applied to interstate telemarketing; its letter cites the Bureau’s notice as DA 26-867. Pragmatic Deliveries also objected by mail in 17-59, defending a petition to notify businesses that use a number for two-factor authentication when the number is disconnected and about to be reassigned.

The FCC published step-by-step call-blocking guides on September 22 for iPhone and Android devices and for AT&T, T-Mobile and Verizon’s app-based services, at fcc.gov/blockit.

Looking ahead

The September 30 meeting will show whether the revocation order adds “one” to the text-keyword provision and whether the follow-up-message window goes into the FNPRM, and whether Vibes’s code-level opt-out or a twelve-month effective date made it in. The 911 Framework NOI will set comment and reply dates when adopted. RMD FNPRM comments close October 9, which is where KYUP, relay attestation and the facilities definition get their next full round. And watch WC 20-174 for iconectiv’s answer to Somos.