Changing trickle-down robonomics
A creative regulatory approach to prevent robocalls has been proposed to the FCC. Would it work? Let’s have a look.
This approach was suggested by ZipDX in a recent series of meetings with Commission staff advisors and in their ex parte notification filings. The proposal includes the following:
- First, the proposal describes the financial incentives for service providers along the call path to look the other way.
- Next, the proposal introduces an economic risk to counter the powerful profit motive.
Follow the money
The ZipDX proposal describes the economic drivers of illegal robocalls:
Intermediates, gateways, terminating providers get about $75 million US annually to deliver illegal robocalls. ZipDX dubs this “trickle-down robonomics.”
These providers have great visibility into illegal robocalls, but they have incentive to look the other way.
Hold each provider in the call path accountable for illegal calls. Collect stiff penalties for carrying illegal call traffic. This changes each provider’s risk/reward calculation.
Conversational and dialer traffic
ZipDX proposes specific measures to identify risky traffic. These measures are based upon call duration, as follows:
|Type||Average Duration||Calls < 1 Minute|
|Conversational||> 3 minutes||50%|
|Dialer||< 1 minute||95%|
Conversational calls typically last more than three minutes; about half of these calls last less than a minute.
Dialer traffic, on the other hand, has average duration less than a minute; 95% of calls are less than a minute. The ZipDX proposal estimates that perhaps half of dialer traffic includes illegal robocalls.
ZipDX maintains that these stats are easy to monitor by each provider along the call path. Each provider would be motivated to set up a reporting system that identifies suspicious traffic.
- Change the Robocall Mitigation Database (RMD) filing to have each provider certify whether they accept dialer traffic.
- If no, the provider handles conversational call traffic only, then they have a safe harbor protection from robocall.
- If yes, then the provider must describe how they monitor dialer traffic. Examples include putting dialer traffic on a separate trunk, monitoring call duration and answer rates, and so forth.
- Hold each provider along the call path accountable for dialer traffic that it accepts.
Would it work?
It’s encouraging to see a specific, detailed proposal that squarely addresses the underlying economic reality.
And it’s helpful to see a knowledgeable observer draw a clear line in the sand with proposed benchmarks to classify conversational and dialer traffic. The proposal applies these standards to averages calculated over hundreds of thousands, or millions, of calls. A provider would not be able to hide much dialer traffic from these averages.
But who would see these averages? A well-intentioned provider could perform the calculations to identify suspicious traffic. A bad actor, however, knows they’re carrying dialer traffic—they don’t need to see the stats.
Neither the FCC nor the Robocall Traceback Consortium could see the stats.
But the next downstream providers would. They would have incentive to monitor call duration. Their risk/reward appetite may be different. They may not want to risk stiff penalties.
Perhaps the risk of enforcement action would compel enough providers to monitor suspicious traffic and question upstream providers who send it. This is the economic leverage that the ZipDX proposal aims to unleash.
- ZipDX ex parte notification letter from April 5, 2022.
- ZipDX presentation from April 19 meeting with legal advisors to Chairwoman Rosenworcel.
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