How The FCC Drive To Bring Call Centers Back To The US Will Affect The Debt Collection Industry

The FCC Action — What It Is

On March 27, 2026, the FCC issued a Notice of Proposed Rulemaking (NPRM) following a March 26 commission vote. As analyzed by Steptoe LLP, the core proposals include:

• An offshore volume cap (30% proposed as a starting point, subject to comment)

• Mandatory disclosure when a call is handled offshore

• A consumer “right to transfer” to a U.S.-based agent, with transfer wait times that cannot exceed domestic queue times

• Prohibition on offshore handling of sensitive consumer information — including bank account numbers, credit card numbers, and Social Security numbers

• Ban on call centers located in designated “foreign adversary” nations (China, Cuba, Russia, etc.)

• English proficiency (“American Standard English”) requirements for offshore agents

• Tracking, reporting, and complaint-handling obligations

The TCPA Hook — How Debt Collectors Get Pulled In

This is the critical nexus for the debt collection industry. The FCC’s primary jurisdiction covers telecom carriers, cable operators, VoIP providers, and satellite providers — not debt collectors directly. However, the NPRM explicitly seeks comment on extending these rules to entities covered by the Telephone Consumer Protection Act (TCPA).

As HWG LLP notes, the FCC is specifically asking whether Section 227(c)’s consumer protection aims support applying the offshore rules to foreign-originated calls to residential subscribers — which directly implicates debt collection outbound calling operations. The FCC is also exploring vicarious liability, asking whether a TCPA-covered entity could be held liable for offshore call center violations by an authorized third-party vendor.

This is not a trivial expansion. Debt collectors are among the largest TCPA-covered call-generating industries in the U.S., and many mid-to-large collectors and debt buyers operate or contract with offshore BPO operations in the Philippines, India, Colombia, and Jamaica.

Direct Operational Impacts on Debt Collectors

Sensitive Data Handling — Near-Certain Compliance Trigger

Even if the TCPA expansion doesn’t materialize, virtually every substantive debt collection interaction involves “sensitive consumer information” as defined in the NPRM: account numbers, SSNs for identity verification, and payment card data. This means that if debt collectors fall within scope at all, their core collection activities — not just peripheral customer service — would need to be handled by U.S.-based agents. Offshore operations would be limited to lower-sensitivity functions like appointment scheduling or general intake.

Cost Structure Disruption

Offshore labor in the Philippines or India typically runs $8–14/hour all-in versus $18–28/hour for comparable U.S. domestic agents. Many collection agencies and debt buyers have constructed their unit economics around offshore cost bases, particularly for high-volume, low-balance portfolios (medical debt, telecom, utilities) where margin is thin. A forced shift onshore — or even a 30% offshore cap — would compress margins materially for these operators.

FDCPA / TCPA Regulatory Layering

The debt collection industry has been pressing the FCC in parallel on separate TCPA reform. As reported by the Consumer Financial Services Law Monitor, ACA International met with FCC Chairman Brendan Carr’s office in June 2025 advocating for revocation of the “Revoke All” rule and harmonization between TCPA and FDCPA/Reg F. The offshore NPRM creates a cross-current: ACA is simultaneously seeking TCPA relief while this NPRM would dramatically expand TCPA’s operational reach if the scope is extended to cover collector-to-consumer outbound calls.

Vendor Contract Exposure

Most larger collection agencies use third-party BPO providers rather than captive offshore operations. If vicarious liability attaches — which the FCC is explicitly asking about — collectors could be held responsible for their vendors’ non-compliance with disclosure scripts, English proficiency standards, and sensitive data routing. This would require substantial vendor contract redrafting and compliance auditing throughout the supply chain.

Parallel Legislative Track

The Keep Call Centers in America Act of 2025 (S. 2495, introduced July 2025) covers all businesses using offshore call centers — not just FCC-regulated entities — and would require disclosure, transfer rights, and a public DOL list of employers offshoring 30%+ of call center work. Companies on the list would be ineligible for federal grants and guaranteed loans for five years. Violations are enforced as FTC Act unfair or deceptive acts. This legislation, if passed, would unambiguously cover debt collection operations without any need for the TCPA hook.

The AI Acceleration Risk

A counterintuitive outcome flagged by CX Network and others: rather than reshoring human agents, many collectors may accelerate deployment of AI-powered collection agents to sidestep the geographic compliance issue entirely. A domestic AI system is neither offshore nor subject to English-proficiency or location-disclosure rules. This could actually reduce the jobs-creation goal of the policy while simultaneously raising new FDCPA questions about AI-to-consumer collection communication disclosures under Reg F.

What to Watch

• Comment period: Opens approximately one month after Federal Register publication (likely May/June 2026). ACA International’s comment will be the key industry filing to track.

• Scope of TCPA extension: The FCC’s decision on whether to bring TCPA-covered entities within the rule is the make-or-break question for the debt collection industry specifically.

• Sensitive data definition: Whether “bank account numbers” is read broadly enough to cover account-level debt information (not just payment data) would be determinative for the offshore restriction.

• Vicarious liability question: If adopted, this would fundamentally restructure the vendor relationship model the collection industry has relied on for two decades.

The rulemaking is still at the NPRM stage, so no rules are final. But the FCC has demonstrated it can move relatively quickly under existing TCPA authority, and the parallel legislative track means the industry faces pressure from two directions simultaneously.