June 22, 2026
TRANSMITTED VIA E-FILING (ECFS)
Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, S.W., Room TW-A325 Washington, D.C. 20554
Re: Reply Comments of Enterprise Communications Advocacy Coalition Improving Customer Service and Protecting Consumers Through Onshoring CG Docket Nos. 26-52, 17-59, 02-278 and 22-2
Dear Ms. Dortch:
On behalf of the Enterprise Communications Advocacy Coalition (“ECAC”), we respectfully submit these Reply Comments in response to the Notice of Proposed Rulemaking (“NPRM”) in the above-referenced proceedings.
I. The Record Does Not Support the NPRM’s Premise That Offshore Customer Service Systematically Harms Consumers
The NPRM rests on the assumption that offshore customer service operations degrade customer experience and increase risk to consumers. The available record does not support that premise.
As commenters have explained, offshore customer service operations are widely used and often provide high-quality service. Responsible Enterprises Against Consumer Harassment (R.E.A.C.H.), Reply Comments of R.E.A.C.H. 1, 7 (June 2, 2026) (arguing that offshore call centers frequently employ well-trained, fluent agents and can deliver “superior” customer experiences); id. at 4 (urging the Commission not to presume offshore interactions are inferior). Moreover, independent industry data reinforce those observations. Survey data from customer contact executives indicate that offshore customer service is widely used, operationally necessary, and generally effective.1
1 CMP Q1 Survey (2026) (n=200 customer contact and customer experience executives across North America, representing a range of industries and company sizes). A substantial majority of surveyed executives report satisfaction with outsourced customer service operations, including satisfaction with their ability to provide reliable service across time zones and customer populations.2
2 Id. Additional survey data similarly show that Marlene H. Dortch, Secretary June 22, 2026 Page 2
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a majority of organizations currently maintain offshore customer service operations, confirming that such models remain a standard component of customer engagement strategies across industries.3
3 Ex. A, CMP (Q2 2026) 1, 1 (n=200 customer contact and customer experience executives across North America, representing a range of industries and company sizes).
These data directly undermine the NPRM’s premise that offshore customer service is inherently inferior. The Commission does not reconcile its generalized concerns regarding offshore operations with evidence showing high levels of satisfaction and continued reliance on those models.
II. The NPRM Fails to Account for How Customer Service Operations Function in Practice
Both R.E.A.C.H. and the Ad Hoc Telecom Users Committee (“Ad Hoc”) explain that offshore customer service reflects deliberate operational design, not incidental outsourcing. R.E.A.C.H. at 4; Ad Hoc Telecom Users Committee, Comments of the Ad Hoc Telecom Users Committee 1, 11 (May 26, 2026).
Ad Hoc emphasizes that businesses make intentional decisions regarding how to structure customer service operations, including where to locate call centers and how to deploy personnel. See Ad Hoc at 10-11 (explaining that companies structure customer service operations based on cost, service quality, and operational needs). These decisions are core business functions, not ancillary communications practices.
R.E.A.C.H. similarly explains that offshore call centers often provide stable, trained, and long-tenured workforces and are used to deliver effective customer service. R.E.A.C.H at 6-7 (noting workforce stability and lower turnover in offshore operations).
Industry data confirm these operational realities. Offshore customer service is frequently used to support continuous, 24/7 coverage and global service availability—capabilities that are central to modern customer service architectures.4
4 CMP Q1 Survey. It is these operational drivers that reflect how companies design customer contact systems to meet the expectations of geographically diverse customer populations.
The NPRM acknowledges these operational considerations but does not meaningfully analyze how proposed caps or transfer requirements would affect them. See Improving Customer Service and Protecting Consumers Through Onshoring, 91 Fed. Reg. 21761, 21763. Moreover, it does not cite to any industry data to support its purpose other than vague conclusory statements. These omissions are significant given the record evidence demonstrating that offshore operations are integral to service continuity as supported by the referenced industry data. Marlene H. Dortch, Secretary June 22, 2026 Page 3
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Additional industry data further demonstrate that customer experience outcomes are driven by workforce characteristics rather than geography. Survey responses show that agents with above-average tenure achieve customer satisfaction scores approximately 11.9 percentage points higher than less experienced agents, underscoring that training, retention, and operational management—not location—are the primary determinants of service quality.5
5 Ex. A 2. These findings reinforce that the drivers of customer experience identified in the record are operational and managerial, not geographic, and therefore are not addressed by the location-based restrictions contemplated in the NPRM.
III. The Proposed Structural Mandates Are Unsupported and Disconnected From Market Reality
The NPRM proposes sweeping structural mandates—including caps on offshore call handling and mandatory transfer requirements—without demonstrating that such measures are necessary or effective.
Ad Hoc correctly observes that the Commission’s approach would regulate internal business operations—including call center location and staffing decisions—based solely on the use of telephone numbers. See Ad Hoc at 5 (warning that the Commission’s theory would extend to “virtually every American business” and regulate internal operations). This represents a substantial expansion of the Commission’s regulatory reach.
The available data confirm that these proposed mandates are disconnected from how the market functions. The survey data collected by CMP indicate that customer contact organizations currently rely on offshore operations at scale and expect to continue or expand that reliance over time.6
6 CMP Q1 Survey. Separate survey data likewise indicate that offshore staffing has become a mainstream feature of customer service operations across respondent organizations.7
7 Ex. A 1. The Commission does not explain how imposing rigid caps—such as the suggested 30 percent threshold—would align with these market realities or improve consumer outcomes.
More fundamentally, the NPRM identifies no data correlating offshore customer service with reduced customer satisfaction, increased complaints, or heightened security risk. Instead, it proposes structural constraints without establishing a factual basis for doing so.
IV. The NPRM Targets Lawful Customer Service Rather Than the Source of Consumer Harm Marlene H. Dortch, Secretary June 22, 2026 Page 4
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Commenters also emphasize that the Commission’s concerns regarding fraud and consumer harm are primarily attributable to unlawful actors, not to legitimate customer service operations. R.E.A.C.H. expressly urges the Commission to focus enforcement on “specific foreign call centers that knowingly utilize unlawful practices” rather than adopting broad restrictions. See R.E.A.C.H. at 2, 5. R.E.A.C.H. further distinguishes between unlawful scam traffic and lawful customer service communications. Id. at 11.
The Commission itself acknowledges that “a very large share” of call center fraud is attributable to scam operations rather than legitimate businesses. See Improving Customer Service and Protecting Consumers Through Onshoring, 91 Fed. Reg. at 21771. Yet the NPRM proposes sweeping restrictions on lawful customer service operations without demonstrating that such restrictions will meaningfully address the sources of harm it identifies.
This mismatch remains unresolved. The Commission has not shown that lawful offshore customer service—subject to contractual, technical, and supervisory controls—presents the same risks as unlawful scam operations. Consistent with this record, available survey data do not identify offshore customer service operations as a primary source of consumer harm; rather, respondents cite factors such as automation and cost pressures as the principal forces shaping customer service delivery models.8
8 Id.
V. Market Participants Are Already Addressing the Relevant Tradeoffs Without Regulatory Intervention
Ad Hoc further explains that customers are sophisticated purchasers capable of evaluating and selecting customer service models that meet their needs. See Ad Hoc at 10-11 (noting that enterprise customers negotiate service terms and select providers based on competitive considerations). The available data are consistent with that observation. CMP concludes that customer contact executives report high levels of satisfaction with outsourced operations and continue to rely on offshore customer service as a core component of their customer engagement strategies.9
9 CMP Q1 Survey. These findings indicate that market participants are effectively addressing the tradeoffs associated with offshore customer service without the need for prescriptive regulatory mandates.
Where the record reflects that businesses are making informed and effective decisions regarding customer service models, the Commission must do more than rely on generalized concerns to justify broad intervention. Marlene H. Dortch, Secretary June 22, 2026 Page 5
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VI. Conclusion
The record developed in this proceeding confirms that the NPRM’s proposed rules are not supported by evidence, do not reflect how customer service operations function in practice, and are not reasonably tailored to the harms the Commission seeks to address.
The Commission should reconsider the proposed structural mandates, including percentage caps and transfer requirements, more clearly distinguish between lawful customer service and unlawful scam activity, and ensure that any final rules are grounded in demonstrable evidence and consistent with the limits of its statutory authority.
Very truly yours,
/s/ Mitchell N. Roth Mitchell N. Roth 1
Exhibit A
Current Trends and Future Expectations for U.S.-based Customer Service
1. Most respondents expect demand for U.S.-based customer service agents to decline
Expected Demand (Next 3-5 Years)
Responses
Decrease
28 (52%)
Increase
14 (26%)
Stay the Same
12 (22%)
Examples of comments:
- AI will improve self-service and reduce call volume.
- AI will make agents more efficient, reducing headcount.
- Cost pressures will continue pushing work offshore.
2. Offshore operations are now the norm
Offshore Staffing
Responses
Yes
37 (64%)
No
21 (36%)
English Proficiency Testing Insights
Domestic Operations
Test for American English Proficiency?
Responses
No
35
Yes
17 Marlene H. Dortch, Secretary June 22, 2026 Page 2
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Not Sure
1
Offshore Operations
Test for American English Proficiency?
Responses
Yes
29
No
5
Not Sure
3
Strong Evidence that Tenure Matters
Average CSAT Results
Agent Group
Average CSAT
Above-average tenure
75.5%
Below-average tenure
65.9%
Concerns About a Standardized English Exam
Concern
Count
No concerns
20
Doesn’t reflect real-world communication
17
Cultural/regional bias
15
Risk of excluding qualified candidates
14
Increased hiring/compliance costs
14
Administrative burden
13
Security and Compliance Findings
The most commonly reported certifications were: Marlene H. Dortch, Secretary June 22, 2026 Page 3
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- PCI-DSS
- SOC 1 / SOC 2
- ISO 27001
- GDPR Compliance
Industry Representation
Largest respondent groups:
- Financial Services (8)
- Travel, Hospitality & Leisure (5)
- Technology & Software (4)
- Healthcare & Life Sciences (3)
- Retail & eCommerce (3)
Satisfaction with Offshore Representatives – Customer Satisfaction
Over Performing Expectations 14
Performing As Expected 15
Under Performing Expectations 4
