Do warning letters curb illegal robocalls?

April 12, 2023

The FCC and FTC have been sending warning letters to gateway service providers identified as carrying suspicious robocalls. Do these letters work? The FTC has recently provided some statistics. Let’s look at the numbers.

The numbers

The FTC works with the Industry Traceback Group, the FCC, and state attorneys general to identify gateway providers that are routing illegal calls. They call this effort their “Project Point of No Entry.” The FTC sends letters to gateway providers identified in traceback warning them that their conduct may violate the Telemarketing Sales Rule.

Here are the results from 2021 through 2023:

24 gateway providers received warning letters from the FTC.
1,043 tracebacks tied these providers to 307 telemarketing campaigns.
- Campaigns included government and business imposters, COVID-10 relief payment scams, and student loan debt relief schemes.
- A single campaign often represents hundreds of thousands or millions of calls.
22 providers significantly curbed or altogether stopped carrying illegal robocalls after receiving warning letters, a 92% drop.
Tracebacks involving these providers dropped from 1,043 to 196 after FTC contact, an 82% decrease.
- Of these 196 tracebacks, 147 are linked to two uncooperative providers.

Takeaways

A cynic might feel that a robocall-friendly provider will simply find another way to carry illegal robocalls. The financial motivation is just too strong.

However, these stats from the FTC provide a ray of hope. A significant portion of providers appears to have chosen a different path—to carry legal calls and stop carrying the bad ones.

Recent robocall trends indicate that this might not be just wishful thinking. While robocalls have been increasing over the past 12 months, many of those appear to be legal calls. Scam robocalls have been on a downward trend.

The FCC’s recent Sixth Order on Call Authentication should reinforce this trend. It will require all providers to take reasonable steps to mitigate illegal robocalls, regardless of their role in the call path, and describe their robocall mitigation plan in the Robocall Mitigation Database. A reasonable robocall mitigation plan must describe the provider’s “Know-Your-Upstream-Provider” procedures and the call analytics they use to identify and block illegal traffic.

For more information on the results of the FTC’s enforcement efforts, see their announcement: FTC Ramps Up Fight to Close the Door on Illegal Robocalls Originating from Overseas Scammers and Imposters.

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