Daily Ex Parte, Sep 2, 2025
TCPA, Direct Video Calling (DVC) into the 911 system, Paramount (CBS) biased and misleading journalism
Filers
American Bankers Association, ACA International, American Financial Services Association, America’s Credit Unions, Edison Electric Institute, Student Loan Servicing Alliance
Intrado Life & Safety, Inc., Communications Service for the Deaf
Center for American Rights
American Bankers Association, ACA International, American Financial Services Association, America’s Credit Unions, Edison Electric Institute, Student Loan Servicing Alliance
Proceeding(s): 02-278
Date of Meeting: August 27, 2025
Date Disseminated: September 02, 2025
Participants:
Jonathan Thessin, American Bankers Association
Michael Pryor, Brownstein Hyatt Farber Schreck, LLP (on behalf of ACA International)
Philip Bohi, American Financial Services Association
James Akin, America's Credit Unions
Aryeh Fishman, Edison Electric Institute
Scott Buchanan, Student Loan Servicing Alliance
Marcus Maher, Senior Legal Advisor to FCC Commissioner Olivia Trusty
Summary of Discussion:
Representatives from a coalition of trade associations (the Associations) met with Marcus Maher, Senior Legal Advisor to Commissioner Olivia Trusty, to discuss two provisions in the Federal Communications Commission's (FCC) February 16, 2024 Report and Order concerning the revocation of consent under the Telephone Consumer Protection Act (TCPA). The Associations argued that these provisions harm consumers and contravene congressional intent and should be rescinded.
The Associations began by explaining that their members—which include banks, credit unions, financial services companies, electric utilities, and student loan servicers—regularly send time-sensitive, non-telemarketing communications to their customers. Examples include fraud alerts, data breach notifications, power outage updates, service restoration information, and payment reminders.
The discussion focused on two main points of contention with the TCPA Order:
The "Revoke All" Provision: The Associations strongly oppose the rule requiring a business to treat a consumer's "stop" request in response to one type of message as a global revocation of consent for all future communications, including those on unrelated matters. They argued this could have severe unintended consequences. For example, a customer replying "stop" to a past-due notice could inadvertently be opted out of critical fraud alerts from their bank or essential power outage notifications from their utility company. This, they contend, creates a "barrier to the normal, expected or desired communications" and could lead to increased fraud or compromise customer safety. They noted that other stakeholders in healthcare and taxpayer advocacy have also raised concerns about this provision.
Non-Standard Revocation Language: The Associations support the part of the Order that standardizes a set of keywords ("stop," "quit," "end," "revoke," etc.) to create a clear method for consumers to revoke consent. However, they object to the accompanying provision that also requires businesses to honor revocation requests using non-standard language if "a reasonable person would understand" it as a request to opt-out. They argue this will lead consumers to use phrases like "I do not want to receive any more texts," which cannot be processed by automated systems. This will frustrate both consumers, whose requests may be delayed, and the businesses, which will have to resort to inefficient, non-automated processes to handle these varied requests.
In summary, the Associations urged the FCC to rescind these two provisions to avoid disrupting the flow of critical, consented-to information between businesses and their customers.
Source: [NOTICE OF EXPARTE, American Bankers Association, ACA International, American Financial Services Association, America’s Credit Unions, Edison Electric Institute, Student Loan Servicing Alliance, https://www.fcc.gov/ecfs/document/108301075321329/1]
Intrado Life & Safety, Inc., Communications Service for the Deaf
Proceeding(s): 21-479
Date of Meeting: August 18, 2025
Date Disseminated: September 02, 2025
Participants:
Intrado Life & Safety, Inc. (Intrado): Lauren Kravetz (Vice President, Government Affairs) and D. Jeremy DeMar (Senior Manager, Government Affairs).
Communication Service for the Deaf (CSD): Christopher Soukup (Chief Executive Officer) and Cameron Papazis (Business Development Manager).
Federal Communications Commission (FCC) Staff:
Robert Aldrich, Legal Advisor, Consumer and Governmental Affairs Bureau (CGB)
Brenda Boykin, Deputy Chief, Policy and Licensing Division, Public Safety and Homeland Security Bureau (PSHSB)
Lisa Edwards, Deputy Chief, CGB
John Evanoff, Chief, Policy and Licensing Division, PSHSB
Michael Scott, Deputy Chief, Disability Rights Office
Suzy Singleton, Chief, Disability Rights Office
William David Wallace, Attorney Advisor, Disability Rights Office
Rachel Wehr, Deputy Chief, Policy and Licensing Division, PSHSB
Summary of Discussion:
Representatives from Intrado Life & Safety, Inc. and Communication Service for the Deaf (CSD) met with staff from the FCC's Consumer and Governmental Affairs Bureau (CGB) and Public Safety and Homeland Security Bureau (PSHSB) to advocate for the integration of Direct Video Calling (DVC) into the 911 system for individuals who are deaf or hard of hearing.
The presentation highlighted the challenges with current emergency communication methods for the deaf community, which includes approximately 11 million people in the U.S. While systems like TTY, Text-to-911, and Video Relay Services (VRS) exist, the presenters focused on the shortcomings of VRS. They argued that relying on a third-party interpreter in an emergency can lead to critical information being lost in translation, delays in response due to the interpreting process, and complications during call transfers. Furthermore, VRS interpreters are not typically subject matter experts in emergency situations.
As a solution, Intrado and CSD promoted DVC, which enables individuals who use American Sign Language (ASL) to communicate directly with an ASL-fluent 911 representative without the need for an intermediary interpreter. This direct communication method is presented as a more effective and equitable form of access to emergency services. A comparison chart in the presentation showed that DVC offers advantages over relay services, including direct-to-number calling, the use of specifically trained representatives, and better tracking of callers who are deaf or hard of hearing, while maintaining ADA and HIPAA compliance.
The core proposal of the meeting was the creation of a pilot program to explore how DVC could be integrated into the 911 emergency response framework. Intrado and CSD informed the FCC that they are in discussions to develop such a pilot and that several Public Safety Answering Points (PSAPs) have expressed interest in participating. They reiterated their previously filed comments, urging the Commission to consider funding the pilot through the Telecommunications Relay Service (TRS) Fund. The presentation also introduced a "DVC as a Service (DVCaaS)" concept, potentially leveraging Intrado's existing Emergency Call Relay Center (ECRC) infrastructure.
During the meeting, FCC staff requested additional information on potential call flow options for incorporating DVC into the 911 system. Intrado and CSD are committed to providing these details at a later date, as they are still under development.
Source: [NOTICE OF EXPARTE, Intrado Life & Safety, Inc., Communications Service for the Deaf, https://www.fcc.gov/ecfs/document/10829987110294/1; https://www.fcc.gov/ecfs/document/10829987110294/2]
Center for American Rights
Proceeding(s): 24-275
Date of Meeting: September 02, 2025
Date Disseminated: September 02, 2025
Participants: Daniel R. Suhr of the Center for American Rights sent an email communication to Erin Boone and Katie McAuliffe, staff in the office of FCC Chairman Brendan Carr.
Summary of Discussion:
The Center for American Rights submitted a letter to Chairman Brendan Carr expressing concerns about the journalistic practices of CBS, the parent company of which (Paramount Global) is a subject of the listed proceeding. The filing argues that CBS has demonstrated a pattern of biased and misleading editing, specifically on its program Face the Nation.
The primary focus of the letter is an August 31, 2025, Face the Nation interview with Homeland Security Secretary Kristi Noem. The Center alleges that CBS "edited for time" the interview in a way that "excised the full story" about the criminal past of Kilmar Abrego Garcia. To support this claim, the filing includes a press release from the Department of Homeland Security (DHS) which accuses CBS of "shamefully" and "deceptively" editing the interview. The DHS statement claims that CBS cut nearly four minutes (over 23%) of the footage, removing Secretary Noem's description of Abrego Garcia as a "known human smuggler, MS-13 gang member, an individual who was a wife beater, and someone who... solicited nude photos from minors." The DHS also states that CBS removed Noem's comments about successful law enforcement actions in Los Angeles and her commitment to fiscal responsibility and departmental hiring standards.
The Center for American Rights argues this incident is not isolated, citing a similar accusation from House Speaker Mike Johnson in October 2024 regarding Face the Nation. The filing also references a previous tweet from Chairman Carr criticizing networks for mischaracterizing Abrego Garcia, and points out that CBS has continued to refer to him as a "Maryland man" or "migrant" despite his background.
As a remedy, the Center for American Rights calls on CBS to fulfill its promise, referenced in a July 2025 FCC order regarding the Paramount Global transfer of control, to appoint an "independent and empowered" ombudsman. This ombudsman would be tasked with conducting prompt reviews when prominent guests, such as a cabinet secretary, accuse a CBS News program of deceptive editing.
Source: [NOTICE OF EXPARTE, Center for American Rights, https://www.fcc.gov/ecfs/document/109021690518756/1; https://www.fcc.gov/ecfs/document/109021690518756/2; https://www.fcc.gov/ecfs/document/109021690518756/3]