FCC to telcos—You cannot be dumb pipes for robocalls
Recently, I had a conversation with Josh Bercu, Vice President of Policy & Advocacy at USTelecom—The Broadband Association, and David Frankel, CEO of ZipDX and Senior Advisor to USTelecom’s Industry Traceback Group. Here are some important takeaways for voice service providers.
Industry Traceback Group
Mr. Frankel was one of the key proponents in creating the Industry Traceback Group. The purpose of my call was to get clarity on questions about the Traceback Group and FCC requirements for service providers to cooperate with the Traceback Group. A podcast of that conversation is available here.
After discussing the Industry Traceback Group, Josh and David explained that in 2020, the Federal Communications Commission (FCC) fundamentally changed the telecom world forever. When it comes to robocalls, telephone service providers are no longer just simple common carriers that must accept and complete every call. Telephone service providers are expected to take steps to prevent illegal calls from originating on their networks. Service providers cannot be dumb pipes for robocalls. They are responsible for knowing their customers and policing their networks.
This profound change in the role of telephone service providers has culminated in two FCC orders. The first was the FCC’s Second Report and Order implementing the TRACED Act (WC Docket No. 17-97) adopted on Sep. 29, 2020. Here are the key points in that order.
- The scope of the order is very broad. It applies to every firm that provides voice services for its customers. Service providers who think this order does not apply to them are mistaken. This order applies to everyone, including Over-The-Top (OTT) VoIP providers, wholesale providers and small providers with less than 100,000 lines.
- Service providers must submit and certify with the FCC a robocall mitigation plan for preventing the origination of robocalls from their network by June 30, 2021. This requirement applies for all calls that are not SHAKEN authenticated.
- Intermediate providers are required to block calls from service providers that have not certified their robocall mitigation plan or SHAKEN implementation with the FCC.
The Fourth Report and Order on robocall blocking (CG Docket No. 17-59) adopted: December 29, 2020 reaffirms and expands the robocall mitigation responsibilities of service providers more explicitly with the following key points:
- The FCC opens the discussion section of this order with “we take further steps to implement the TRACED Act and require voice service providers to better police their networks.”
- All voice service providers must respond to traceback requests from the FCC, civil and criminal law enforcement, and the Traceback Group, fully and in a timely manner.
- Voice service providers must mitigate illegal traffic when notified of it by the FCC.
- Voice service providers must adopt affirmative, effective measures to prevent new and renewing customers from using their network to originate illegal calls. All originating voice service providers must know their customers and exercise due diligence in ensuring that their services are not used to originate illegal traffic.
The new FCC regulations do not prescribe how service providers should comply. However, the Wireline Bureau did issue recommended Caller ID Authentication Best Practices. This document is a good starting point for service providers who are thinking through how they will modify their business processes to comply with the new responsibility of being more than just a dumb pipe when it comes to robocalls.
Thank you, David and Josh, for helping me and TransNexus customers better understand the new FCC requirements and what must be done for compliance.
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