Every call must be routable to a US-based agent on request, with no longer wait time than a direct domestic call. That requires a routing decision before the call is queued — not after a customer has been waiting on hold.

Passwords, MFA codes, SSNs, bank accounts, credit card numbers — all must be handled exclusively by US-based agents (or fully automated systems where appropriate). Across voice, chat, email and text. That requires the routing layer to know, in real time, what kind of transaction the customer is initiating.

The rule prohibits handling calls in designated jurisdictions. This is data residency enforcement at the routing layer.

When a call is handled by an offshore agent, the customer must be told at the start of the call, told the country and told their right to transfer. That requires an automated front-end before the human gets the call.

Percentage offshore, transfer requests, transfer wait times, English proficiency testing results — all must be reportable to the FCC on demand. Your data infrastructure has to capture every routing decision and its outcome.