The requirements include more voice service providers, and the FCC is also seeking comments on notifications for blocked calls. These topics are slated for discussion at ACA’s Washington Insights Fly-In May 15-17.
05/10/2023 10:30 A.M.
4.5 minute read
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Call blocking requirements for voice service providers are back on the Federal Communications Commission’s agenda this month as part of its “multi-pronged approach” on this issue.
In a report and order, the FCC is expanding mandatory call blocking requirements for providers by:
- Extending the 24-hour traceback requirement to cover all voice service providers in the call path.
- Originating voice service providers will also be required to block illegal call traffic when notified of those calls by the FCC.
- Extending the requirement to take reasonable and effective steps to ensure all voice service providers are not using their networks to carry or process a high volume of illegal calls. This means providers accepting call traffic from an “upstream provider” must know their processes.
A further notice from the FCC would:
- “Propose and seek comment on further action to combat illegal robocalls, including by requiring all terminating providers to offer analytics-based blocking, requiring all voice service providers to block calls based on a reasonable do-not-originate list, and requiring non-gateway intermediate and terminating providers to block in certain instances.
- Propose to set a base forfeiture for failure to comply with the rule requiring voice service providers to take affirmative, effective measures to prevent new and renewing customers from originating illegal calls and to allow that forfeiture to be increased up to the maximum for non-common carriers.
- Seek comment on a number of other call blocking issues, including on requiring a single Session Initiation Protocol (SIP) Code for immediate notification to callers whose calls are blocked based on analytics and requiring terminating providers to display caller name information when they provide an indication to the call recipient that the call has received ‘full’ or ‘A’ attestation.”
There is an additional opportunity for stakeholder comment through a notice of inquiry focused on the tools voice service providers use to stop illegal calls and the current state of call labeling, including the extent it is used and its accuracy.
The FCC also seeks comments on which SIP codes voice service providers terminating calls that have been blocked should be required to use.
As you may recall, the last time the FCC addressed this issue, it authorized use of the 603 SIP code along with 607/608. Since then, the industry developed the 603+ code.
The FCC is now seeking comments on whether the 603+ code should be required for immediate notifications or if it should require code 608 or 603.
SIP codes are programmed to inform callers with certain responses.
In addition to advocating for SIP Codes 607 and 608 in meetings with the FCC, ACA International and joint industry trade groups have also called for the commission to sunset the use of SIP Code 603, which only signals to the caller that the recipient declined the call, not that the call was subject to blocking by voice service providers, ACA previously reported.
ACA, with its Telephone Consumer Protection Act coalition, as it has done several other times, filed comments outlining callers’ concerns. ACA continues to have discussions with the FCC about this topic.
In March, the FCC adopted new rules on illegal robocall mitigation and to expand requirements for voice service providers to implement the STIR/SHAKEN call authentication framework.
The rulemaking (PDF) closes a significant gap in the STIR/SHAKEN call authentication framework, increases robocall mitigation requirements for all providers, enacts more robust enforcement tools, and seeks feedback on more steps to further improve the effectiveness of the STIR/SHAKEN framework, ACA previously reported.
Call blocking and labeling and text message blocking issues will be discussed at ACA’s Washington Insights Fly-In May 15-17. There is still time for members to join us—register today!
ACA and joint industry trade association partners have also advocated with the FCC to ensure important illegal robocall blocking measures do not impact calls from legitimate businesses consumers want and need, as documented in a letter (PDF) recapping a meeting with these groups and the FCC on its Advanced Methods to Target and Eliminate Unlawful Robocalls.
They also submitted a letter (PDF) before a March meeting with proposed additions to the FCC’s report and order on text message blocking, including the point of contact for blocked text messages.
The joint industry trade groups appreciate the FCC’s quick actions to help curb illegal robotexts and overall support regulation; however, there is more work to be done in the text message blocking rule, which ACA members can read about here.
Meanwhile, the FCC’s modified rule on call exemptions and obtaining consumers’ consent will take effect on July 20, 2023, meaning compliance is required for certain call exemptions and call limits by that date, ACA previously reported.
To learn how this could impact your business and call flow, ACA members can listen to this recent ACA Huddle episode presented by Mark Brennan and Katy Milner, partners at Hogan Lovells.
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