On Monday this week (October 3, 2022), the FCC announced plans to remove 7 companies from the robocall mitigation database for non-compliance – unless they get their act together in the next 14 days.
Which service providers?
Per the order, the following 7 service providers received a notice from the FCC:
- Global UC
- Horizon Technology
- Morse Communications
- Sharon Telephone
- SW Arkansas Telecom
Why? What did they do?
From reviewing the FCC’s notices, along with the original robocall mitigation filings from these companies, it seems that these companies basically didn’t provide any remotely plausible robocall mitigation plan to the FCC. Some of them said their robocall mitigation plans were confidential, and didn’t upload them to the database, some provided screenshots of documentation related to STIR/SHAKEN – that had nothing to do with their specific plans.
You can see all their filings in the database – where you can view the attachment (supposedly the robocall mitigation plan) at the far right of their listing.
What does this mean?
I think this is pretty big news, because up until now I’d seen no evidence that the FCC was reading the plans – instead it seemed that the effectiveness of the plans would only really be tested if you were found to be the source of illegal robocalls. This announcement changes that.
The FCC has clearly decided that some proactive enforcement is justified. The seven service providers targeted here clearly have egregiously inadequate filings in the database – they basically haven’t filed a plan at all, perhaps because they didn’t understand what they were required to do. They also seem to have ignored the FCC’s attempts to reach out to them to fix the problem – hence things escalated to this public notice.
What does this mean for me?
To my mind, there are two key consequences for all other service providers.
- Go back and re-read your robocall mitigation plan (the one in the database). The FCC has started by addressing the very worst filings, but they may well take action against the “pretty bad” filings next. Your plan needs to describe specific reasonable steps that you have taken to avoid originating illegal robocall traffic – you can’t view this is a box-checking exercise. Your plan needs to be appropriate and you need to actually follow it.
- Depending what happens in the next 14 days, you may be required to stop accepting traffic from the above 7 carriers. That’s the big consequence of being removed from the database – other carriers must stop accepting your traffic. If you operate an end-office switch, you probably don’t have direct trunks to these folks, so that’s not a big deal, but if you’re an intermediate provider (class 4) with a large set of network trunks, you need to make sure you’re keeping an eye on enforcement actions so you can cut people off when the FCC requires it.
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