Chesham, UK – 31 Mar 2026
Sytel, a UK-based specialist in predictive dialing and real-time interaction management, has submitted an ex parte filing to the Federal Communications Commission (FCC) on two active proceedings covering robocall mitigation and caller identification.
The submission makes a direct point: predictive dialing solutions are not yet capable of delivering both strong productivity and reliable compliance at the same time. Any move toward lighter-touch regulation on the assumption that they do would be premature.
Sytel CEO Michael McKinlay commented:
“One option under consideration is a move toward a no-rules environment, based on an assumption that simply isn’t true: that predictive dialers have matured. They haven’t. The engineering challenge of operating effectively within a disciplined rule set such as the Federal Trade Commission (FTC)’s Telemarketing Sales Rule (TSR) is demanding, and most systems were never designed to meet it.”
While the TSR sits with the FTC rather than the FCC, it remains the only fully developed behavioral standard for outbound calling in the United States. Under the TSR with a 20% live answer rate and abandonment capped at 3% of live calls, a dialer may abandon up to just six calls per thousand dialled. Delivering meaningful predictive gain within that limit requires highly precise pacing.
In practice, most dialers do not operate effectively within that constraint. They either breach the rules, or remain compliant by reverting to progressive dialing, delivering little or no predictive gain, while still presenting themselves as predictive.
Karl Perkins, former CTO of Avaya, commented:
“There is a persistent assumption that predictive dialing is a solved problem. It isn’t. The industry has largely avoided building systems that can operate effectively within behavioral constraints, while maintaining performance. The issue is not the existence of dialing standards, but the absence of a standard that drives real engineering innovation, and thus meet the needs of both consumers and business.”
McKinlay added:
“The FCC is considering a much broader market for dialers, not just telemarketing, and that could be a very effective spur to innovation, to the benefit of both consumers and legitimate businesses. But without a standard to work to, the incentive to innovate is weak and consumers will pay the price. The TSR provides a credible, field-tested standard, fit for adoption by the FCC.”
On caller identification and branded calling, Sytel supports the Commission’s direction but makes a clear distinction: transparency helps consumers decide whether to answer a call, but it does not control how dialers behave once the call is made. Identity reform and behavioral discipline for dialers must operate together; one without the other is not sufficient.
McKinlay concluded:
“There may come a point where behavioural limits can be relaxed, when transparency is widespread, dialers are genuinely well engineered, and market discipline is effective. But we are not there yet. The way to get there is through a clear and credible standard that encourages better technology, not by stepping back too early.”
Sytel’s filing is available via the FCC’s Electronic Comment Filing System.
