Robocall mitigation compliance strategy

The TRACED Act and subsequent FCC orders require action by June 30, 2021. Voice service providers need a compliance strategy. In this blog post, we review the requirements and things you should think about while developing your plan.

Compliance requirements

By June 30, 2021, every voice service provider must do the following:

  1. Use STIR/SHAKEN, or, if eligible, a Robocall Mitigation Program, on every call you originate with U.S. NANP calling numbers.
  2. File a Robocall Mitigation Certification with the FCC in a new Robocall Mitigation Database.
  3. Block calls with U.S. NANP calling numbers from upstream providers that don’t have a certification on file in the new Robocall Mitigation Database.
  4. Cooperate fully and quickly with robocall traceback requests.

Let’s take a look at these requirements and strategic considerations for each.

business planning

STIR/SHAKEN or robocall mitigation

The FCC’s First Report and Order mandates STIR/SHAKEN for all calls by June 30, 2021. The order also allows deadline extensions for some providers and call types.

Any provider accepting an extension on STIR/SHAKEN must have and use a Robocall Mitigation Program on every call that it originates without STIR/SHAKEN. You must either use STIR/SHAKEN or robocall mitigation on every call you originate.

The FCC Fourth Report and Order, states that it will “require voice service providers to take steps to effectively mitigate illegal traffic when notified by the Commission.” This requirement can be invoked on any provider for originating illegal robocalls, whether they’re using STIR/SHAKEN or not.

Strategic considerations

  • Do you qualify for an extension, or do some calls you originate qualify for an extension?
  • Should you do STIR/SHAKEN anyway, even if you are eligible for an extension?
    • Your business customers will want their outbound calls signed to improve call completion.
    • Your subscribers would be more comfortable answering verified calls.
  • You might need a Robocall Mitigation Program anyway, even if you’re doing STIR/SHAKEN. The FCC will require robocall mitigation if they find that you have originated illegal robocalls. A Robocall Mitigation Program would help you avoid that situation.

Robocall Mitigation Certification filing

Every provider must file a certification in the FCC Robocall Mitigation Database, whether they are using STIR/SHAKEN, robocall mitigation or both.

The certification must include detailed practices that can reasonably be expected to significantly reduce the origination of illegal robocalls.

The service provider must be doing the things listed in its certification filing.

Strategic considerations

  • What should your robocall mitigation practices be?
  • How can you ensure that you’re doing these things by the time you file your certification?
  • How would you describe these practices in sufficient detail in your filing?

Block calls from uncertified upstream providers

The FCC Second Report and Order prohibits intermediate providers and terminating providers from accepting voice traffic directly from any voice service provider that does not appear in the Robocall Mitigation Database.

Note that this filing would not be checked in real time for each call. Providers would periodically check the Robocall Mitigation Database to see if filings are present for upstream providers.

Also note that this requirement applies to gateway providers that accept calls with U.S. NANP calling numbers from upstream foreign service providers. Foreign service providers that initiate such calls must file a certification in the Robocall Mitigation Database.

Concerns have been raised about this provision by members of CTIA, who filed a petition for partial reconsideration to request that the FCC rescind this requirement.

ZipDX has asked the FCC to allow gateway providers to apply their own Robocall Mitigation Program to such calls and treat upstream foreign providers as customers.

Strategic considerations

  • Prepare a list of upstream providers, including foreign providers.
  • Ask foreign providers if they are aware of this certification filing requirement and if they intend to comply.
  • Consider whether you would be prepared to accept robocall mitigation responsibility for uncertified upstream foreign providers if the FCC accepts the ZipDX proposal.

Cooperate with robocall traceback

The FCC Fourth Report and Order mandates full and rapid cooperation with robocall traceback requests.

Some providers might not be familiar with how robocall traceback works. We’ve published a brief overview of the process and a video podcast with common questions and answers.

Strategic considerations

  • Identify and train traceback coordinator(s) and backup(s) so they can respond to traceback requests.
  • Train staff that traceback requests are important.
    • If a traceback request comes in through an unexpected channel, make sure it is quickly forwarded to a traceback coordinator.
  • Respond to traceback requests promptly.

TransNexus robocall mitigation solutions

We offer robocall mitigation solutions in our ClearIP and NexOSS software products. We can help you deploy them quickly and easily.

In addition, we can help you plan, prepare, and complete your Robocall Mitigation Certification filing. Your filing will demonstrate to the Commission that your voice service business has deployed effective robocall mitigation measures in production.

Contact us today to learn how we can help you tailor a robocall mitigation program to your circumstances and satisfy compliance requirements.

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