Truth in Caller ID Act and lawful caller ID presentation

See also

Sources

1. 1
   The RAY BAUM'S Act section 503 amendments to 47 U.S.C. 227(e) took effect six months after the FCC prescribed implementing regulations; the codifier's note records the FCC order released 2019-08-05 with the final rule effective 2020-02-05 (84 FR 45669).

   47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · Effective Date of 2018 Amendment note (Pub. L. 115-141, div. P, title V, sec. 503(a)(5)) · Checked 2026-10-14
2. 2
   FCC 24-120 describes A-level STIR/SHAKEN attestation as requiring the signing provider to have established a verified association with the telephone number used for the call, while B-level requires an authenticated customer relationship without number verification.

   Call Authentication Trust Anchor, Eighth Report and Order (FCC 24-120) · paragraph 10 · Checked 2026-10-14
3. 3
   The Truth in Caller ID Act is Public Law 111-331 (S. 30), approved December 22, 2010; it added subsection (e) to 47 U.S.C. 227 and redesignated the former subsections (e)-(g) as (f)-(h).

   Public Law 111-331 - Truth in Caller ID Act of 2009 · Public Law 111-331 heading and approval date · Checked 2026-10-14
4. 4
   FCC 24-104 holds that unsolicited call-backs received by the person whose number was spoofed are a harm under the Truth in Caller ID Act; the spoofed number belonged to the spouse of a former state party chair who was not involved in the calls.

   Steve Kramer, Forfeiture Order, FCC 24-104 · paragraphs 7 and 32 · Checked 2026-10-14
5. 5
   Under 47 U.S.C. 227(e)(5)(A)(i) the FCC forfeiture for a Truth in Caller ID Act violation may not exceed $10,000 per violation, or three times that amount for each day of a continuing violation, with a total cap of $1,000,000 for any single act or failure to act in a continuing violation.

   47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(5)(A)(i) · Checked 2026-10-14
6. 6
   FCC 21-35 found none of the 60 caller IDs Rising Eagle used were assigned to it or its clients, and held that a client directing the use of unassigned numbers does not negate the dialer operator's knowing causation of inaccurate caller ID.

   John C. Spiller, Jakob A. Mears, Rising Eagle Capital Group LLC et al., Forfeiture Order, FCC 21-35 · paragraphs 15-16 · Checked 2026-10-14
7. 7
   An outsourced contact center that, on a client's behalf, presents the client's own customer service number, which is answered and accepts do-not-call requests during business hours, is using the express FCC and FTC substitution allowance and lacks the harmful intent the Truth in Caller ID Act requires.inferred

   47 CFR 64.1601 - Delivery requirements and privacy restrictions · 47 CFR 64.1601(e)(1) read with 47 CFR 64.1604(a) and FCC 11-100 para 25 · Checked 2026-10-14
8. 8
   47 U.S.C. 227(e)(5)(B) provides that a person who willfully and knowingly violates subsection (e) shall upon conviction be fined not more than $10,000 per violation, or three times that amount for each day of a continuing violation, in lieu of the section 501 fine.

   47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(5)(B) · Checked 2026-10-14
9. 9
   47 U.S.C. 227(e)(8)(B) defines caller identification service as any service or device designed to give its user the telephone number of, or other information about the origination of, a call or text message, and expressly includes automatic number identification services.

   47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(8)(B) · Checked 2026-10-14
10. 10
    47 U.S.C. 227(e)(8)(C) defines text message to include SMS and MMS but to exclude real-time two-way voice or video and messages sent over an IP-enabled messaging service to another user of the same service.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(8)(C)(ii)-(iii) · Checked 2026-10-14
11. 11
    47 U.S.C. 227(e)(8)(E) defines voice service as a service interconnected with the PSTN that furnishes voice communications to an end user using North American Numbering Plan resources, including fax transmissions to a fax machine.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(8)(E) · Checked 2026-10-14
12. 12
    The FCC implemented the Truth in Caller ID Act in a Report and Order, FCC 11-100, WC Docket No. 11-39, adopted June 20, 2011 and released June 22, 2011.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · caption and cover page · Checked 2026-10-14
13. 13
    FCC 19-73, the Second Report and Order implementing RAY BAUM'S Act section 503 (WC Dockets 18-335 and 11-39), was adopted August 1, 2019, released August 5, 2019, published at 84 FR 45669 on August 30, 2019, and effective February 5, 2020.

    Implementing the Anti-Spoofing Provisions of the RAY BAUM'S Act, Final rule, 84 FR 45669 (FCC 19-73) · FR heading, DATES and paragraph 25 · Checked 2026-10-14
14. 14
    In FCC 11-100 the Commission acknowledged benign caller ID manipulation, citing domestic violence shelters and doctors who call from a cell phone but choose to transmit their office number as the calling number.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraph 9 · Checked 2026-10-14
15. 15
    FCC 11-100 treats harm under the Act as a broad concept encompassing financial, physical and emotional harm, and calls spoofing for harassment or stalking an egregious violation.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraph 22 · Checked 2026-10-14
16. 16
    FCC 11-100 states that manipulating or altering caller ID information without the requisite harmful intent does not violate the Truth in Caller ID Act.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraph 25 · Checked 2026-10-14
17. 17
    In FCC 11-100 the Commission declined to adopt any exemptions beyond law enforcement and court orders, rejecting proposed exemptions including one for legitimate business reasons, for victim service providers and for private investigators.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraphs 24-25 · Checked 2026-10-14
18. 18
    47 CFR 64.1601(e)(1) requires that the telephone number a telemarketer provides as caller ID must permit any individual to make a do-not-call request during regular business hours.

    47 CFR 64.1601 - Delivery requirements and privacy restrictions · 47 CFR 64.1601(e)(1), final sentence · Checked 2026-10-14
19. 19
    FCC 11-100 footnote 17 (attached to paragraph 8) cites a commenter whose members operate inbound and outbound contact centers, some of which manipulate caller ID for legitimate business reasons.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraph 8, footnote 17 · Checked 2026-10-14
20. 20
    47 CFR 64.1601(e)(1) states it is not a violation for a telemarketer to substitute, for the name and number used in or billed for the call, the name of the seller on whose behalf the call is placed and the seller's customer service telephone number.

    47 CFR 64.1601 - Delivery requirements and privacy restrictions · 47 CFR 64.1601(e)(1), second sentence · Checked 2026-10-14
21. 21
    FCC 11-100 states that the Truth in Caller ID rules do not relieve anyone engaged in telemarketing of the obligation to transmit caller ID information under 47 CFR 64.1601(e).

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraph 36 · Checked 2026-10-14
22. 22
    47 U.S.C. 227(e)(5)(A)(iv) bars an FCC forfeiture under subsection (e) for a violation that occurred more than four years before the required notice or notice of apparent liability was issued.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(5)(A)(iv) · Checked 2026-10-14
23. 23
    FCC 21-35 states that direct evidence of specific intent is rarely available and infers intent to defraud from conduct, and notes that spoofing used in an unlawful robocalling campaign can indicate intent to cause harm.

    John C. Spiller, Jakob A. Mears, Rising Eagle Capital Group LLC et al., Forfeiture Order, FCC 21-35 · paragraph 4 note 9; paragraphs 19-20 · Checked 2026-10-14
24. 24
    In FCC 24-104 (adopted September 26, 2024, released September 30, 2024) the FCC imposed a $6,000,000 forfeiture on Steve Kramer under 47 U.S.C. 227(e) and 47 CFR 64.1604 for spoofed AI-voice robocalls before the New Hampshire primary.

    Steve Kramer, Forfeiture Order, FCC 24-104 · paragraphs 1, 21 and 49 · Checked 2026-10-14
25. 25
    Lawful presentation under the Truth in Caller ID Act does not ensure an A-level STIR/SHAKEN attestation: when a contact center presents a client's number, the signing originating provider must itself have a verified association with that number.inferred

    Call Authentication Trust Anchor, Eighth Report and Order (FCC 24-120) · paragraphs 10 and 18 read with 47 CFR 64.1604 · Checked 2026-10-14
26. 26
    In FCC 11-100 the Commission declined a DOJ proposal that spoofing providers verify a user's authority to use a substituted number; the Truth in Caller ID rules contain no requirement to prove authorization to use a presented number.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraphs 38-40 · Checked 2026-10-14
27. 27
    FCC 24-104 states that recipient reliance is not necessary to establish intent to defraud under the Truth in Caller ID Act, and that the Act does not require willful or repeated violations for a forfeiture.

    Steve Kramer, Forfeiture Order, FCC 24-104 · paragraphs 27 and 37 · Checked 2026-10-14
28. 28
    In FCC 19-73 the Commission concluded that one-way VoIP falls within voice service for the anti-spoofing rules, reading the NANP-resource requirement as applying to the called end user rather than the spoofer, and counting indirect PSTN interconnection.

    Implementing the Anti-Spoofing Provisions of the RAY BAUM'S Act, Final rule, 84 FR 45669 (FCC 19-73) · paragraphs 17-19 · Checked 2026-10-14
29. 29
    47 CFR 64.1600(g) defines information regarding the origination to include the telephone number, the name, location information and other information about the source or apparent source of a call, so a false calling name can fall within the prohibition, not only a false number.

    47 CFR 64.1600 - Definitions (Subpart P, Calling Party Telephone Number; Privacy) · 47 CFR 64.1600(g) · Checked 2026-10-14
30. 30
    FCC 19-73 excludes from text message those messages sent between users of the same IP-enabled service (naming WhatsApp, iMessage, Google Hangouts and Skype) and treats RCS on the same basis, while including short code messages for this rulemaking.

    Implementing the Anti-Spoofing Provisions of the RAY BAUM'S Act, Final rule, 84 FR 45669 (FCC 19-73) · paragraphs 10, 12 and 13 · Checked 2026-10-14
31. 31
    FCC 24-120 permits third-party STIR/SHAKEN signing only if calls are signed with the obligated provider's own certificate, requires each obligated provider to obtain its own SPC token, and keeps attestation-level decisions with that provider.

    Call Authentication Trust Anchor, Eighth Report and Order (FCC 24-120) · paragraphs 14, 20 and 28 · Checked 2026-10-14
32. 32
    In FCC 21-35 (released March 18, 2021) the FCC imposed a $225,000,000 forfeiture on John C. Spiller, Jakob A. Mears and their Rising Eagle and JSquared entities for spoofed robocalls.

    John C. Spiller, Jakob A. Mears, Rising Eagle Capital Group LLC et al., Forfeiture Order, FCC 21-35 · paragraphs 1-2 and 13 · Checked 2026-10-14
33. 33
    47 CFR 64.1604(a) implements the statute: no person in the US, or outside it when the recipient is in the US, may knowingly cause a caller ID service to transmit or display misleading or inaccurate caller ID information in connection with a voice or text messaging service with intent to defraud, cause harm, or wrongfully obtain anything of value.

    47 CFR 64.1604 - Prohibition on transmission of inaccurate or misleading caller identification information · 47 CFR 64.1604(a) · Checked 2026-10-14
34. 34
    47 CFR 64.1604(c) states that a person or entity that blocks or seeks to block its caller ID information under 64.1601(b) is not liable under 64.1604(a), and that this does not relieve telemarketers of their duty under 64.1601(e) to transmit caller ID.

    47 CFR 64.1604 - Prohibition on transmission of inaccurate or misleading caller identification information · 47 CFR 64.1604(c) · Checked 2026-10-14
35. 35
    47 CFR 64.1604(b) exempts only two categories from the prohibition: lawfully authorized investigative, protective or intelligence activity of a US, State or local law enforcement agency or a US intelligence agency, and activity under a court order that specifically authorizes caller ID manipulation.

    47 CFR 64.1604 - Prohibition on transmission of inaccurate or misleading caller identification information · 47 CFR 64.1604(b)(1)-(2) · Checked 2026-10-14
36. 36
    Section 1 of Public Law 111-331 gives the short title as the Truth in Caller ID Act of 2009, even though the law was approved in December 2010.

    Public Law 111-331 - Truth in Caller ID Act of 2009 · Sec. 1. Short Title · Checked 2026-10-14
37. 37
    47 U.S.C. 227(e)(6)(A) lets a State's chief legal officer bring a parens patriae civil action in a US district court to enforce subsection (e) or impose its civil penalties.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(6)(A) · Checked 2026-10-14
38. 38
    Under 47 U.S.C. 227(e)(6)(B)-(C) a State must serve written notice and a copy of the complaint on the FCC before filing (or immediately on filing if prior notice is not feasible), and the FCC may intervene, be heard and appeal.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(6)(B) and (C) · Checked 2026-10-14
39. 39
    47 U.S.C. 227(e)(2) states that nothing in subsection (e) may be construed to prevent or restrict any person from blocking the capability of a caller identification service to transmit caller identification information.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(2) · Checked 2026-10-14
40. 40
    47 U.S.C. 227(e)(1) makes it unlawful to cause any caller identification service to knowingly transmit misleading or inaccurate caller identification information with the intent to defraud, cause harm, or wrongfully obtain anything of value, unless the transmission is exempted under paragraph (3)(B).

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(1) · Checked 2026-10-14
41. 41
    Since the 2018 amendment, 47 U.S.C. 227(e)(1) also reaches any person outside the United States if the recipient of the call or text is within the United States.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(1); 2018 amendment note for Subsec. (e)(1) · Checked 2026-10-14
42. 42
    47 U.S.C. 227(e)(3)(B)(ii) requires the FCC's regulations to exempt transmissions in connection with any authorized activity of a law enforcement agency or a court order that specifically authorizes caller identification manipulation.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(3)(B)(ii) · Checked 2026-10-14
43. 43
    47 U.S.C. 227(e)(1) applies in connection with any voice service or text messaging service; before the 2018 amendment the phrase was in connection with any telecommunications service.

    47 U.S.C. 227 - Restrictions on use of telephone equipment (United States Code, 2023 Edition) · 47 U.S.C. 227(e)(1); 2018 amendment note (Pub. L. 115-141 sec. 503(a)(1)) · Checked 2026-10-14
44. 44
    47 CFR 64.1601(e)(1) requires any person or entity engaged in telemarketing to transmit caller ID information that includes either CPN or ANI and, when made available by the telemarketer's carrier, the name of the telemarketer.

    47 CFR 64.1601 - Delivery requirements and privacy restrictions · 47 CFR 64.1601(e) and (e)(1) · Checked 2026-10-14
45. 45
    47 CFR 64.1601(e)(2) prohibits any person or entity that engages in telemarketing from blocking the transmission of caller ID information.

    47 CFR 64.1601 - Delivery requirements and privacy restrictions · 47 CFR 64.1601(e)(2) · Checked 2026-10-14
46. 46
    FCC 11-100 holds that third-party spoofing services are not exempt and violate the Act when they cause misleading caller ID with the required intent, while declining to impose extra record-keeping or verification duties on them.

    Rules and Regulations Implementing the Truth in Caller ID Act of 2009, Report and Order, WC Docket No. 11-39, FCC 11-100 · paragraphs 40 and 42 (Third-Party Spoofing Services) · Checked 2026-10-14
47. 47
    FTC guidance states that calling equipment not capable of transmitting caller ID is no excuse for failing to transmit it under the TSR.

    Complying with the Telemarketing Sales Rule · Protecting Consumers' Privacy > Transmitting Caller ID Information · Checked 2026-10-14
48. 48
    FTC guidance states that telemarketers who took all available steps to ensure caller ID transmission on every call are not liable for isolated, inadvertent transmission failures.

    Complying with the Telemarketing Sales Rule · Protecting Consumers' Privacy > Transmitting Caller ID Information · Checked 2026-10-14
49. 49
    16 CFR 310.4(a)(8) states it is not a violation to substitute the name of the seller or charitable organization on whose behalf the call is placed and its customer or donor service telephone number, which is answered during regular business hours.

    16 CFR 310.4 - Abusive telemarketing acts or practices (Telemarketing Sales Rule) · 16 CFR 310.4(a)(8), proviso · Checked 2026-10-14
50. 50
    FTC guidance says a telemarketing service bureau calling for multiple clients may transmit a client-seller's customer service number and name, provided its phone company can transmit that information.

    Complying with the Telemarketing Sales Rule · Protecting Consumers' Privacy > Transmitting Caller ID Information · Checked 2026-10-14
51. 51
    The FTC Telemarketing Sales Rule at 16 CFR 310.4(a)(8) makes it an abusive practice to fail to transmit the telephone number and, when made available by the telemarketer's carrier, the name of the telemarketer to the recipient's caller ID service.

    16 CFR 310.4 - Abusive telemarketing acts or practices (Telemarketing Sales Rule) · 16 CFR 310.4(a)(8) · Checked 2026-10-14
52. 52
    Presenting a number the caller is not authorized to use is not unlawful per se under 47 U.S.C. 227(e), but because the FCC counts call-backs to the number's real holder as harm, it creates material exposure that the harmful-intent element will be found.inferred

    Steve Kramer, Forfeiture Order, FCC 24-104 · paragraph 32 read with FCC 11-100 paragraphs 25 and 38-40 · Checked 2026-10-14
53. 53
    FCC 24-120 notes that an originating provider may lack direct knowledge of the users of a value-added provider's call-center platforms, and points to reasonable know-your-customer protocols rather than ruling on specific arrangements.

    Call Authentication Trust Anchor, Eighth Report and Order (FCC 24-120) · paragraph 18 · Checked 2026-10-14
54. 54
    FCC 24-104 states that a Truth in Caller ID Act violation is not dependent on the content of the call.

    Steve Kramer, Forfeiture Order, FCC 24-104 · paragraph 5 · Checked 2026-10-14

Documents

Cite this page

WarmTransfer. (2026, October 14). Truth in Caller ID Act and lawful caller ID presentation. WarmTransfer. https://warmtransfer.net/knowledge/caller-id-spoofing-rules

@misc{warmtransfer-caller-id-spoofing-rules,
  title  = {Truth in Caller ID Act and lawful caller ID presentation},
  author = {{WarmTransfer}},
  year   = {2026},
  url    = {https://warmtransfer.net/knowledge/caller-id-spoofing-rules},
  note   = {Verified 2026-10-14}
}