The FCC is (slowly, slowly) increasing robocall enforcement. It issued a
cease and desist letter, and directed all voice service providers to take
steps to effectively mitigate suspected illegal robocall traffic made by
or on behalf of the following: (1) Urth Access, LLC (Urth Access); (2)
Fire Data LLC; (3) US Acquisitions LLC; (4) Dawood & Dawood; (5) Dawood
and Company; (6) their individual associates; and (7) associated entities
(collectively, the Student Loan Robocall Operation).
https://www.fcc.gov/document/fcc-orders-blocking-student-loan-scam-robocall-campaign
As always consult with your own corporate lawyers. The FCC order has lots
of words which mean different things to a lawyer.
The FCC gets grumpy when companies fail to reply to its letters.