Abandonment
The subscriber hangs up or never connects, for example during a hold after the representative drops. Some of these are valid changes lost. You want this low, and you want the exact step where people leave.
Telecom carrier changes
Telecom carrier change verification under 47 CFR 64.1120
In telecom, how a carrier change is verified is set by federal rule. Independent third party verification is one of the allowed methods, and the rule expressly permits automated verification systems, with conditions. Below is the rule, requirement by requirement, and how our agent meets each one.
The TPV Buyer's Checklist
What to measure, and what to make any TPV vendor prove, including us.
Verification call
Ended
Illustrative
Carrier change
Telemarketing
TEL-7702
-
Identity and authority Confirmed“Yes, I’m the account owner.”
-
Services changing Confirmed“Yes, the business lines.”
-
Carrier change Asked for a person“Wait, is this switching my long distance? Can I talk to someone?”
-
Authorization Not reached
Transferred to a live verifier
Stopped at carrier change confirmation
- Reason
- Subscriber asked for a live person
- Recording
- Attached, full call
- Next step
- Order held until the live verification ends
The rule
What 47 CFR 64.1120 covers
The rule governs changes to a subscriber's preferred carrier for telecommunications service. A carrier may not submit a change without the subscriber's authorization and a verification of that authorization (paragraph (a)(1)).
It allows three ways to verify (paragraph (c)): a written or electronically signed letter of agency, an electronic authorization the subscriber places from the number being changed, or an appropriately qualified independent third party who obtains the subscriber's oral authorization. The rest of this page is about the third.
Two limits on scope. Commercial mobile radio service providers are excluded from these verification requirements as long as they are not required to provide equal access to common carriers for toll services (paragraph (a)(3)). And states can enforce these procedures for intrastate service and add their own (paragraphs (a) and (c)(4)). Check your own case with counsel.
The rule also prohibits material misrepresentation on the sales call. When a consumer credibly alleges one, the burden of proof shifts to the carrier to rebut it (paragraph (a)(1)(i)(A)). A complete recording of the subscriber confirming what they authorized is part of that rebuttal. And a carrier that becomes the subject of an FCC forfeiture action for violating the third party verification process is suspended from using that process for five years (paragraph (b)).
Read the full text on the eCFR. This page summarizes it as of 2 October 2026 and is not legal advice.
Slamming rules
The rule, requirement by requirement
Each requirement an automated third party verifier has to meet, what the rule says, and how our agent meets it.
-
Independence
The third party must not be owned, managed, controlled or directed by the carrier or its marketing agent, must have no financial incentive to confirm carrier change orders for them, and must operate in a location physically separate from them (paragraph (c)(3)).
How our agent meets it: Automatdo is an independent company, not owned or directed by any carrier we verify for. We are paid per attempt, so a confirmation earns us nothing a rejection does not. Our systems run separately from the carrier's and its sales agents'.
-
Automated systems are allowed
Automated third party verification systems and three-way conference calls may be used, as long as the requirements that follow are met (paragraph (c)(3)(i)).
How our agent meets it: the agent is an automated verification system in this sense. The rest of this list is how it meets the conditions.
-
The sales representative drops off
A carrier or sales representative who starts a three-way call, or a call through an automated verification system, must drop off once the three-way connection is established (paragraph (c)(3)(ii)).
How our agent meets it: the script asks whether the representative is still on the line before verification begins, and the verification does not proceed while they are.
-
The required verification data
At a minimum the verification must elicit the date; the subscriber's identity; confirmation that the person on the call is authorized to make the change, wants to make it, and understands it is a carrier change and not an upgrade, bill consolidation or anything else; the names of the carriers affected, not including the displaced carrier; the telephone numbers to be switched; and the types of service involved (paragraph (c)(3)(iii)).
How our agent meets it: each element is a scripted question with its own recorded answer in the structured result, so you can show which element was confirmed and how.
-
Nothing misleading, no marketing
Any description of the change must not be misleading, and the verifier may not market the carrier's services. If the subscriber has questions for the sales representative, the verifier must tell them that completing the verification authorizes the change (paragraph (c)(3)(iii)).
How our agent meets it: the agent reads only the approved description of the change. Questions outside the approved clarification paths are not answered on the call, and the statement about completing the verification is part of the script.
-
The language of the sale
Verification must be conducted in the same language that was used in the underlying sales transaction (paragraph (c)(3)(iv)).
How our agent meets it: the order carries the language of the sale. If the program does not cover that language, the verification stops and the result says why.
-
Recorded in its entirety
Third party verifications must be recorded in their entirety (paragraph (c)(3)(iv)).
How our agent meets it: every call is recorded from start to finish, and the recording travels with the result.
-
A live person at any time
Automated systems must give consumers the option to speak with a live person at any time during the call (paragraph (c)(3)(iv)).
How our agent meets it: asking for a person is a defined path at every point in the script, and it transfers the call.
Measuring it
One completion rate, three outcomes, in telecom terms
A single completion rate hides three different results. For carrier changes they look like this.
Rejection
The subscriber thinks they are getting an upgrade or a bundle discount, not a carrier change, or is not the person authorized on the account. The rule's required elements exist to catch exactly this. A rejection rate near zero means the control never fires.
False pass
A carrier change recorded as verified when the recording shows the subscriber did not agree, or did not understand it was a carrier change. That is a slam with a clean-looking verification attached.
Why we built it
Where TPV started
Carrier changes are where third party verification started, and the classic automated verifier still works the way it did then: recorded prompts, keypad answers, a list of words that count as yes. That design meets the letter of a script. It struggles with a subscriber who wants to know whether this is the long-distance thing, or who answers a yes-or-no question with a story.
How the agent works, and the five things to make any vendor prove
FAQ
Questions about 47 CFR 64.1120
What is 47 CFR 64.1120?
The FCC rule that governs how a telecommunications carrier verifies a subscriber's authorization before submitting a change to their preferred carrier. It is the core of the federal anti-slamming rules, and it sets out three ways to verify, one of which is independent third party verification (47 CFR 64.1120).
Is automated third party verification allowed for carrier changes?
Yes. Paragraph (c)(3)(i) allows automated third party verification systems and three-way conference calls, provided the verification meets the requirements on the sales representative dropping off, content, language, recording and live-person access in paragraphs (c)(3)(ii) to (iv).
What must a carrier change verification include?
At a minimum: the date of the verification; the identity of the subscriber; confirmation that the person on the call is authorized to make the change, wants to make it, and understands it is a carrier change rather than an upgrade, bill consolidation or anything else; the names of the carriers affected (not including the displaced carrier); the telephone numbers to be switched; and the types of service involved (paragraph (c)(3)(iii)).
Does the sales rep have to drop off the TPV call?
Yes. A carrier or sales representative who starts a three-way call or a call through an automated verification system must drop off once the three-way connection is established (paragraph (c)(3)(ii)).
Do automated TPV systems have to offer a live person?
Yes. Automated systems must give consumers the option to speak with a live person at any time during the call (paragraph (c)(3)(iv)).
Who counts as an independent third party verifier?
One that is not owned, managed, controlled or directed by the carrier or its marketing agent, has no financial incentive to confirm carrier change orders for them, and operates in a location physically separate from them (paragraph (c)(3)).
Does 47 CFR 64.1120 apply to wireless carriers?
Commercial mobile radio service providers are excluded from these verification requirements as long as they are not required to provide equal access to common carriers for toll services (paragraph (a)(3)). States can also enforce the procedures for intrastate service and add their own. Check your own case with counsel.
Free download
The TPV Buyer's Checklist
Bring it to a vendor call: the number that matters, the nine numbers to make any vendor separate, the five things to make them prove, and the two questions that sort vendors fastest.
Talk to Ryan
Talk to Ryan about verifying carrier changes
Tell me what you verify and roughly how many a month, and I will reply by email. If you would rather talk it through, pick a time on my calendar.
Pick a time on my calendar
Ryan Schuetz
Founder, Automatdo