Updated requirements for direct access to phone numbers
At their September meeting, the FCC updated its rules for direct access to telephone numbers. The announcement headline promotes the rules as curbing illegal robocalls, however, the changes cover a wide range of compliance goals. Let’s have a look.
There are many details in the new rules for direct access to numbering resources. However, these rules can be grouped and summarized into three broad categories:
- Applicants must disclose and keep current information about their ownership, including foreign ownership.
- Applicants must certify their compliance with a broad range of federal and state rules.
- The application review, rejection, and revocation processes used by the Wireline Competition Bureau are updated.
Ownership reporting rules
An interconnected VoIP provider authorized to request numbering resources directly from the Numbering Administration shall:
- Maintain the accuracy of all contact information, certifications, and ownership or affiliation information in its application.
- If any of this information changes, then the provider must file a correction and each applicable state within 30 days of the change.
Applicant compliance certifications and acknowledgments
Applicants for direct access to telephone numbers must acknowledge the following:
- Direct access to numbering resources is subject to compliance with Commission numbering rules, numbering authority delegated to states, and state laws, regulations, and registration requirements.
- Applicants must file requests for numbers with the relevant state commissions at least 30 days before requesting numbers from the Numbering Administrators.
In addition, applications must make the following certifications:
- Will not use the numbers to knowingly transmit or facilitate illegal robocalls.
- Has fully complied with STIR/SHAKEN and robocall mitigation requirements and filed a certification in the Robocall Mitigation Database.
- Complies with its 911 obligations.
- Complies with Access Stimulation rules.
- Has filed FCC 477 and 499 forms or explanation why not.
- Complies with fund contribution obligations, including:
- Universal Service Fund
- Relay Service
- NANP and LNP administration.
- Possesses the financial, managerial, and technical expertise to provide service.
- Must include the names of key personnel.
- No party to the application is subject to a denial of Federal benefits according to section 5301 of the Anti-Drug Abuse Act of 1988.
- Declaration, under penalty of perjury, that all statements are true and accurate.
Whew. As you can see, these rules cover a lot of ground in using number access as a compliance enforcement mechanism.
Application review and authorization oversight
The key change to the application review process is that applicants with foreign ownership will not be reviewed with streamlined processing. The Wireline Competition Bureau can also non-streamline the review process for other reasons, at its discretion.
Applications can be rejected, and authorization can be revoked, for a variety of reasons, including:
- Granting the authorization would not be in the public interest.
- An applicant with foreign ownership presents a risk.
- Applicant made a false or misleading statement.
These rules become effective 30 days after publication in the Federal Register, except for most of the certifications, which require review for the Paperwork Reduction Act by the Office of Management and Budget. Those rules will go into effect after the OMB completes its review and an effective date is set and announced.
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