A bipartisan coalition of attorneys general (AGs) representing each state and Washington D.C. joined forces with the Federal Trade Commission (FTC) and the Department of Justice (DOJ). They have announced their unified commitment to an initiative known as ‘Operation Stop Scam Calls,’ which has already made a significant impact. Illinois AG Kwame Raoul — a fervent advocate for consumer rights — underscored this commitment, saying, “[c]ompanies responsible for these illegal, annoying calls must be held accountable.”
Operation Stop Scam Calls: A Closer Look
The initiative takes a targeted approach to illegal telemarketing, including robocalls. Enforcement efforts focus on the telemarketers, the companies that employ them, and the lead generators who craftily gather and supply consumer telephone numbers to robocallers and others. The program also zeroes in on Voice over Internet Protocol (VoIP) service providers, notorious for facilitating billions of illegal robocalls every year.
Effects and Achievements so Far
The crackdown effort is producing substantial results. The FTC has already initiated 167 cases against illegal robocallers and Do Not Call violators. These actions have led to defendants being ordered to pay more than $2 billion. The FTC has collected more than $394 million from these fines, a significant portion of which has been directed back to defrauded consumers. In conjunction, 48 federal and 54 state agencies have brought forth more than 180 enforcement actions as a part of Operation Stop Scam Calls.
Continuity of Efforts
The initiative is not a shift in focus for the states or the federal government. Instead, it builds on existing bipartisan efforts to curb illegal telemarketing and robocalls. In September 2022, a bipartisan coalition of 51 AGs submitted comments to the Federal Communications Commission (FCC) concerning its proposal to expand anti-robocall rules focused on illegal and fraudulent robocalls. In the letter, the AGs expressed strong support for enhanced regulation for domestic providers. They even suggested additional measures such as short compliance deadlines and the mandatory blocking of all illegal call traffic when alerted by the FCC.
Takeaway: A Focus on Consumer Protection
Consistent with the recent surge in headline-grabbing issues such as opioids, student loans, and tobacco, state and federal authorities have not abandoned their mission to protect consumers against deceptive and manipulative trade practices in other industries. This cross-party assembly of resources amply demonstrates that the commitment to safeguarding consumers from the onslaught of illegal telemarketing from both state and federal authorities continues.
Troutman Pepper State Attorneys General Team
Ashley Taylor – Co-leader and Firm Vice Chair Ashley is a partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group and co-leader of the State Attorneys General practice. He focuses primarily on federal and state government regulatory and enforcement matters involving state attorneys general, the Consumer Financial Protection Bureau (CFPB), and the Federal Trade Commission (FTC). Drawing upon his experience as a deputy attorney general, Ashley has developed an extensive consumer practice with regard to the consumer financial services industry. | |
Clay Friedman – Co-leader Clay is a partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group and co-leader of the State Attorneys General practice. Informed by nearly a decade in a state attorneys general office, and more than 25 years in private practice, Clay spends much of his time representing clients in singular or multistate regulatory actions. Clay has repeatedly led teams before all 50 state attorneys general and also handles matters with the Federal Trade Commission, the Consumer Financial Protection Bureau, and other local, state and federal agencies. | |
Judy Jagdmann Judy is a partner in the firm’s Regulatory Investigations, Strategy and Enforcement (RISE) practice, based in the Richmond office. She brings experience serving as chair and commissioner of the Virginia State Corporate Commission (VSCC) from 2006 through 2022, which includes regulating the utilities, insurance, banking, and securities industries. She also served as Virginia’s attorney general from 2005-2006. | |
Stephen Piepgrass Stephen represents clients interacting with, and being investigated by, state attorneys general and other enforcement bodies, including the CFPB and FTC, as well as clients involved with litigation, particularly in heavily regulated industries. | |
Avi Schick A former deputy attorney general of New York, Avi applies his experience in bet-the-company matters, representing clients in criminal and civil investigations and enforcement actions before state and federal regulators, prosecutors and enforcement agencies. | |
Michael Yaghi Michael handles high-profile state attorneys general, FTC, and CFPB investigations by advising clients through these complex government inquiries. He assists clients through the entire life cycle of investigations, from regulatory enforcement through formal litigation. | |
Ketan Bhirud As a former government official at the state and federal level, Ketan leverages extensive experience in the public and private sectors to skillfully represent client interests. | |
Tim Bado Tim is an attorney in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, with a primary focus on financial services litigation. | |
Chris Carlson Chris represents clients in regulatory, civil and criminal investigations and litigation. In his practice, Chris regularly employs his prior regulatory experience to benefit clients who are interacting with and being investigated by state attorneys general. | |
Natalia Jacobo Natalia is an associate in the firm’s business litigation practice. She recently received her J.D from the University of California, Davis School of Law. | |
Namrata Kang Namrata is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. Her work includes advising clients in regulatory investigations and compliance matters, in addition to representing clients in civil litigation matters. | |
Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general. | |
Susan Nikdel Susan is an associate in the firm’s Consumer Financial Services Practice Group, and focuses her practice on consumer financial services matters. She has defended several of the nation’s largest and most influential financial institutions in individual and class action litigation involving the Telephone Consumer Protection Act (TCPA), Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and other consumer privacy statutes. Susan also represents banks, fintechs, and financial services companies in connection with regulatory examinations and investigations brought by the CFPB, state attorneys general, and the California Department of Financial Protection and Innovation. | |
John Sample John represents clients in a wide variety of general and complex litigation matters, shareholder disputes, products liability, and privacy claims. | |
Whitney Shephard Whitney is an attorney in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. She represents clients facing state and federal regulatory investigations and enforcement actions, as well as related civil litigation. | |
Trey Smith Trey is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement practice. His experience includes serving as a summer associate at the firm in 2021. | |
Daniel Waltz An experienced litigator, Daniel advises and represents regional, national and international companies, financial institutions and insurers in all facets of business, complex commercial and insurance coverage litigation. He is committed to working with his clients to find creative solutions to meet their needs. | |
Stephanie Kozol Stephanie is Troutman Pepper’s senior government relations manager in the state attorneys general department. |