On July 29, 2025, Sens. Ruben Gallego (D-AZ) and Jim Justice (R-WV) introduced the Keep Call Centers in America Act of 2025. The act targets the offshoring of call center operations, imposes new disclosure rules for customer service interactions, and ties federal funding eligibility to domestic operations. Oversight of foreign call centers is not a new concept for financial institutions, as regulators have issued guidance on the topic since the early 2000s. For financial services providers, where customer service and compliance are already tightly regulated, the act will have significant operational and strategic implications. Banks, credit unions, mortgage servicers, and fintech companies that currently rely on offshore call centers will need to prepare for the compliance burdens and operational adjustments the legislation requires.
Link to Key Provisions Key Provisions
1. Applicability
For purposes of the act, the term “employer” refers to any business enterprise that operates a call center and either employs 50 or more individuals (not counting part-time employees) or employs 50 or more individuals who, collectively, work at least 1,500 hours per week (excluding overtime). A “part-time employee” is defined as any employee who works an average of fewer than 20 hours per week or who has been employed for fewer than six of the 12 months preceding the date on which notice is required under the act.
2. Public List of Employers with Offshore Call Centers
The act directs the secretary of labor to create and maintain a publicly available list of employers that relocate a call center overseas or outsource at least 30% of a call center’s work to a foreign provider. Employers must give the secretary of labor at least 120 days’ advance notice before such relocation or outsourcing, and noncompliance can trigger civil penalties of up to $10,000 per day. Once an employer is added to the list, it remains on the list for up to five years unless it brings the work back to the United States and meets specific staffing requirements. For financial institutions, this listing could impact both public perception and eligibility for federal support. The act does not include directions for employers that are already utilizing offshore call centers.
Removal from the List
The secretary of labor must remove an employer from the list if certain conditions are met. Specifically, an employer will be removed if it has relocated a call center from outside the United States to a domestic location and the new call center employs as many or more workers than the overseas center it replaced. Alternatively, an employer that previously outsourced call center work may also be removed from the list if it amends its contract to require that all call center work be performed within the United States.
3. Federal Funding Restrictions
Appearing on the public list has immediate financial consequences. Companies on the list become ineligible for federal grants or guaranteed loans for a period of five years. If a company with an existing federal award is later added to the list, it must pay monthly penalties equal to 8.3% of the total award and may see the award canceled after a year if it remains listed. Although waivers may be granted in limited cases involving national security, significant U.S. job loss, or environmental harm, waivers will be the exception rather than the rule. The law also requires agencies (a federal or state executive agency or a military department) to give contracting preference to employers not appearing on the public list, and mandates that any call center work performed under a federal contract be conducted entirely within the United States.
4. Mandatory Customer Service Disclosures
One year after enactment, the act will require businesses engaged in customer service communications to disclose the physical location of their customer service agents at the start of each interaction. If the agent is outside the United States, the customer must be informed of their right to request an immediate transfer to a U.S.-based agent. Businesses that use artificial intelligence (AI) for customer service must also disclose its use at the outset and offer a transfer to a human agent located domestically. These obligations apply regardless of whether the customer service is performed in-house or by a third-party vendor. Financial institutions will therefore need to adjust scripts, technology platforms, and operational workflows to comply. Annual certification of compliance to the Federal Trade Commission (FTC) will be required, and violations will be treated as unfair or deceptive acts under the FTC Act.
There are several exceptions to the disclosure requirements regarding the location of customer service agents. First, the requirements do not apply when all employees or agents participating in the customer service communication are physically located within the United States. Second, the requirements are waived if a consumer knowingly initiates contact with a foreign business or address, and the consumer is aware, or reasonably should be aware, that the representative is located outside the United States. Third, communications related to emergency services are exempt. Finally, the FTC has the authority to exclude certain business entities or types of customer service communications from these requirements if exceptionally compelling circumstances justify the exclusion.
Link to Impact on Financial Services Businesses Impact on Financial Services Businesses
For financial services companies, the act presents a multifaceted compliance and operational challenge. Institutions will need to conduct a full audit of their call center arrangements, both domestic and international, and review all vendor agreements to ensure offshore providers follow the required notice, disclosure, and transfer protocols. They will also need to evaluate their exposure to federal grants, guarantees, and contracts, as offshore call center operations could jeopardize critical funding sources. Beyond the regulatory consequences, the public nature of the public list means that customer and investor perception could be at stake, potentially affecting brand reputation in a sector where trust and service quality are paramount.
1. Compliance Complexity
Banks, credit unions, mortgage servicers, and fintech companies often rely on offshore call centers for cost efficiency. The act’s notification, certification, and disclosure requirements introduce new compliance layers — with the FTC, Department of Labor, and contracting agencies all involved.
2. Funding & Contracting Risks
For institutions that receive federal loan guarantees, grants, or contracts (e.g., Community Development Financial Institutions, SBA lenders, or Ginnie Mae issuers), offshore call center operations could jeopardize eligibility. Even temporary outsourcing could trigger multi-year ineligibility.
3. Technology & Vendor Management
The disclosure mandates extend to third-party vendors. Financial institutions will need to:
- Review vendor contracts to ensure compliance.
- Implement call routing that enables immediate transfer to U.S.-based staff.
- Incorporate AI usage disclosures into scripts and systems.
4. Reputational Considerations
The public list could influence consumer perception. For financial brands that rely heavily on trust, appearing on this list might have marketing and customer loyalty consequences beyond the regulatory penalties.
Link to Practical Steps for Financial Institutions Practical Steps for Financial Institutions
- Audit Call Center Footprint – Map all in-house and outsourced call center operations, including virtual agents.
- Review Federal Funding Exposure – Identify current or anticipated grants, guarantees, or contracts that could be at risk.
- Revise Vendor Contracts – Add provisions requiring advance notice of any offshore relocation and compliance with disclosure requirements.
- Plan for Disclosure Protocols – Update scripts, CRM systems, and AI interfaces to meet location and AI-use disclosure rules.
- Engage Compliance Early – Coordinate across compliance, legal, IT, and operations to avoid penalties and protect eligibility for federal programs.
Link to Final Thoughts Final Thoughts
The Keep Call Centers in America Act of 2025 reflects a broader federal policy shift toward linking access to federal benefits with domestic job retention and operational transparency. For financial services businesses, its provisions go beyond symbolic support for U.S.-based employment; they create real compliance, funding, and reputational considerations. Now is the time for institutions to engage legal, compliance, IT, and operations teams to assess current practices, update procedures, and ensure that all customer service operations, whether internal or outsourced, are aligned with the requirements of this new legislation.
Bradley’s Banking & Financial Services team will continue to monitor the progression of the act to answer questions and assist industry participants in meeting their compliance requirements.