TRACED Act Timeline: What’s Next for the Legislation in 2020


Hogan Lovells US LLP outlines rulemakings and requirements for the Federal Communications Commission.

1/13/2020 14:30

The Federal Communications Commission is tasked with several rulemakings and reports to Congress under the recently passed Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act.

The landmark legislation, aimed at mitigating illegal robocalls, was signed by President Donald Trump on Dec. 30, 2019.

There are several deadlines for the FCC to meet under the law, as outlined in a recent report from Hogan Lovells US LLP Lead Innovation Partner Mark Brennan and Counsel Arpan Sura.

The FCC deadlines are:

  • March 30, 2020: Issue rules to establish a registration process for a consortium that conducts private-led efforts to trace back the origin of suspected illegal robocalls.
  • April 28, 2020: Initiate a proceeding to protect called parties from one-ring scams.
  • June 29, 2020: The FCC must begin a proceeding to determine how its policies regarding access to numbering resources can be modified to reduce access to numbers by potential illegal robocallers.
  • June 29, 2020: The FCC must establish an advisory committee to be known as the Hospital Robocall Protection Group.
  • July 27, 2020: Annual Public Notice seeking comment on private-led efforts to trace back the origin of suspected unlawful robocalls.
  • Sept. 25, 2020: Promulgate regulations to implement the Act’s civil forfeiture provisions.
  • Dec. 24, 2020: The Hospital Robocall Protection Group must issue best practices regarding to how service providers can combat unlawful robocalls made to hospitals, how hospitals can better protect themselves, and how Federal and state governments can help combat these calls.
  • Dec. 30, 2020: This is the deadline for multiple requirements, including a report to the House Committee on Energy and Commerce and the Senate Commerce Committee on analysis of the extent to which providers have implemented call authentication frameworks and assessment of the efficacy of call authentication frameworks.
  • June 23, 2021: Conclude a proceeding to assess the extent to which the voluntary adoption of the Hospital Robocall Protection Group’s suggested best practices can be facilitated to protect hospitals and other institutions.
  • June 30, 2021: The FCC must require IP Networks to implement STIR/SHAKEN and Non-IP Networks to take “reasonable measures to implement effective call authentication framework.”

Members may view the complete report from Hogan Lovells US LLP on ACA’s online Advocacy Resource Center.

ACA is also working on an upcoming webinar focused on more details about how the TRACED Act timeline may impact ACA members. Stay tuned for more details. Brennan also shared his insights on a recent episode of ACA Cast “Dissecting the TRACED Act” with ACA Vice President and Senior Counsel Federal Advocacy Leah Dempsey.

Advocacy opportunities are also available at the upcoming Washington Insights Fly-In, May 19-21, in Washington, D.C. Registration is available now. More details to come!

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