Reply comments on FCC proposed robocall rules

Reply comments on the FCC’s third inquiry and eighth set of proposed robocall rules were quite active. This article summarizes the reply comments and recurring themes.

Recurring themes

Here are a few recurring themes we noticed in these reply comments:

  • Several reply comments responded to allegations in the first round of comments that analytics engines are mislabeling numbers as spam likely then selling number reputation repair services to correct their mislabeling.
    • Some said that these are nascent technologies that need time to develop, while others said that they have redress procedures in place.
  • There was widespread support for Rich Call Data, though many said it’s too soon for the Commission to mandate it.
  • Many reply comments mentioned problems with improper attestation levels.
    • A B-level attestations should only be made by originating providers that know the identity of the caller.
  • There was support for call notification.
    • There was a mix of support for SIP 608 and SIP 603+.
    • Several urged the Commission to allow one year for implementation of the chosen method.


There was a total of 174 pages of reply comments from 16 submissions. We’ve summarized the reply comments below. If you’d like more information, you can click the filer’s name above each summary to read that organization’s filing.

ACA Connects - America’s Communications Association

  • If the Commission mandates blocking, it should set a reasonable timeline for compliance, at least six months.
  • The Commission should affirm that existing analytics-based blocking tools in the marketplace today are compliant.
  • A mandate should be flexible.
  • If the Commission requires DNO blocking, then it should affirm that the ITG DNO list is reasonable.

Cloud Communications Alliance

  • The Commission should not mandate analytics-based blocking.
    • Some methods, such as call duration, might block legal calls.
    • The Commission should pause until the industry has implemented a uniform standard call blocking notification method.
  • The Commission should take action to address and minimize mislabeling of calls.
  • The Commission should encourage implementation of Rich Call Data.
  • The Commission should require blocking entities to send either SIP 608 or SIP 603+ call blocking notification.

Competitive Carriers Association

  • The Commission should not mandate analytics-based call blocking but take a flexible approach instead.
  • If the Commission mandates analytics-based call blocking, it should allow at least 12 months for implementation.
  • It’s premature to require terminating providers to display a caller name on calls with full A-level attestation.
  • It’s also premature to mandate call labeling rules.


  • Labeling error incidents are anecdotal examples involving nascent technologies that are still developing.
  • Encourages the Commission to take a light touch approach toward nascent technologies such as branded calling and Rich Call Data.
  • The Commission should focus on inaccurate call signing practices that are degrading STIR/SHAKEN data quality.

Electronic Privacy Information Center, National Consumer Law Center, Public Knowledge

  • The Commission should mandate analytics-based blocking.
  • The Commission should implement its proposed base forfeiture.
  • Calls that appear to be scams should always be blocked, not labeled.
  • Until the problem of rented DIDs is resolved, it might not be prudent to implement Rich Call Data.

Hiya, Inc.

  • Hiya uses spam reports from call recipients and other intelligence to accurately identify spam callers. This process is done prior to, and is not influenced by, any decision to add a brand to the call.
  • Hiya and other primary analytics engines support a redress process whereby businesses that believe they are being inappropriately labeled can register their numbers with


  • The Commission should not mandate any additional call blocking requirements, particularly those that are analytics-based, until call blocking improves and inadequacies in the redress process are fixed, including call blocking notification.
  • INCOMPAS prefers SIP 608 but suggests that in the alternative the Commission consider SIP 603+. Most importantly, INCOMPAS urges the Commission to mandate a means for call blocking notification and set a deadline.
  • New bae forfeitures should only be imposed if a service provider had intent to allow its network to deliver illegal calls and failed to take reasonable corrective action.

National Opinion Research Center

  • The Commission’s “highly likely to be illegal” standard is not well defined and is far too subjective to be considered reasonable.
  • Call blocking notification has not yet been implemented.
  • NORC has experienced instances when its calls were tagged as spam, fraud, or were blocked. In some instances, its numbers were retagged after they were cleared.
  • Repeated mislabeling of legal, legitimate calls demonstrates that the analytics are not reasonable. This should not be made worse by mandating that carriers use analytics which repeatedly demonstrate poor results.
  • Achieving an acceptable call completion rate should not require a legitimate legal caller to pay third parties to sanitize the numbers it uses.
  • SIP 603+ fails to offer the same type of actionable information as SIP 608.

NCTA - The Internet & Television Association

  • Consumers like call labeling. They can decide whether to answer. Therefore, call labeling does not require the same regulatory oversight as call blocking.
  • Legitimate callers have redress avenues available that do not entail paying third-party analytics engines.
  • Rich Call Data holds great promise, but regulatory intervention would be premature.
  • The Commission should allow at least 12 months to implement SIP 603+.

Numeracle, Inc.

  • Current branded calling is proprietary, anticompetitive, and sometimes insecure.
    • Numeracle noted one analytics engine provides an out-of-band solution to improve protection against spoofing branded calls, for a fee.
  • Rich Call Data has wide support.
  • Numeracle notes that CTIA’s BCID is a superior solution to the branded calling solutions on the market that suffer from security concerns and control by a small number of gatekeepers.
  • Numeracle described a college admissions office that engaged Numeracle to help with false call labeling. The spam labels did not disappear until Numeracle resumed purchasing monitoring services from TNS.

Somos, Inc.

  • The Commission should ensure that providers use a DNO list that is far more comprehensive that the ITG DNO Registry.
  • The Commission should not delay the implementation of DNO list blocking.

Transaction Network Services, Inc.

  • If call labeling was not functioning properly, the Commission would have heard from consumers and consumer groups.
  • Some have spun conspiracy theories that call labels are manipulated to promote branded calling, but nothing is further from the truth.
  • There is no need for heavy handed Commission regulation in call labeling. It would be more efficient to allow the industry to develop solutions than for the Commission, which lacks the resources, information, and/or capability to do so.
  • The Commission should refrain from adopting a Rich Call Data mandate at this time.

Twilio, Inc.

  • Branded calling driven by Rich Call Data will be the best solution to enable consumers to know that a number is verified and the calling entity is accurately identified.
  • It would be premature for the Commission to mandate any particular caller name verification framework now.
  • The Commission should not prescribe requirements related to CNAM.
  • Twilio supports expedited timeline for adoption and use of the SIP code(s) the Commission selects for call blocking notification.

USTelecom - The Broadband Association

  • Call labeling is popular with consumers.
  • The analytics engines offer so callers can register legitimate numbers and avoid having them blocked, which is free and separate from any branded caller services they may offer.
  • The Commission should allow Rich Call Data, which has tremendous long-term potential, to mature and develop.
  • The Commission should reaffirm that the ITG DNO list is reasonable.
  • SIP 603+ is the best solutions for call blocking notification.


  • Consumers must be the top priority (as opposed to calling parties).
  • Call labeling is different than call blocking because the caller can leave a voicemail.
  • SIP 603+ is the best option for call blocking notification.
  • It’s too soon to mandate that providers pass Rich Call Data.
  • The Commission must step up enforcement against fraudulent and lax signing practices.
  • A B-level attestation should be provided only by the originating carrier who knows the identity of the calling party.

Voice on the Net Coalition

  • The Commission should investigate why most calls are not signed when received by the terminating carrier.
  • The Commission should address anti-competitive call labeling.
    • Voice service providers and enterprise callers should not be forced to purchase expensive branded calling solutions from the entities responsible for mislabeling.
  • The Commission should require all voice service providers to accept Rich Call Data on a competitively neutral basis.
  • The Commission should allow at least one year to implement a new call blocking notification code.

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