May 11, 2022

Petition To Delay Call Blocking Notifications Rules Submitted to FCC

In 2020, the Federal Communications Commission (FCC) issued its "Fourth Report and Order" on how carriers should address call labeling and call blocking notifications for illegally placed calls. However, a petition was filed by USTelecom in 2021 to update the standards on how this should be achieved. Two voice service providers (VSPs) have received citations from the FCC for failure to comply.

Petition to Delay Call Blocking Notification Rules

It was ordered that any entity providing voice services must respond to all traceback requests in a timely manner. Service providers must also take necessary steps toward mitigating illegal call traffic after receiving written notice of the illicit activity. Additionally, the order required all voice service providers to create and enact measures toward preventing both new and current customers or clients from using the entity’s services for illegal calls.

Call Blocking Obligations for Carriers

The FCC requires all voice service providers (VSPs) to "effectively mitigate" illegal traffic on their networks. This means they must adopt call blocking or labeling policies to minimize robocalls reaching their consumers. Carrier obligation consists of three main parts.

  • Respond to Traceback Requests – VSPs must respond to a traceback request filed by the Commission, law enforcement, and the Traceback Consortium in a timely manner.
  • Enforce Mitigation Requirements – VSPs must investigate illegal traffic identified by the Commission's Enforcement Bureau and either a) take actions to mitigate this behavior or b) provide a reasonable conclusion on why calls are not illegal.
  • Exercise Diligence in Services – VSPs must know their customers and ensure that illegal calls do not have access to high-volume origination services.

These steps are put in place to ensure that voice service providers take reasonable steps to mitigate illegal traffic on their networks.

Traceback Consortium Enforcement

Despite network position or STIR/SHAKEN implementation status, any carrier had to meet all requests for enforcement as immediately as possible as established per the TRACED Act. Any law enforcement entity was encouraged, though not compelled, to direct any potential infringements through the Traceback Consortium. after which, if the FCC were to notice a distinct pattern of a carrier or other voice service provider directly in violation, the FCC would take action.

One of the stipulations of the Consortium’s affirmative and effective implementation measures requests that carriers and all other voice services providers know who their customers are. This stipulation can be met by requiring photo identification, proof of address, business information, and any other legally identifying documents. Thereby employing due diligence in achieving the rules set forth by the Consortium to abate illegal calls from fraudulent actors.

For customers requiring access to higher-than-average call origination services, voice providers must more thoroughly investigate identity and take steps to thwart the abuse of privileges if and when reported.

Transparency in Call Blocking Redress

In addition, the FCC issued guidelines for redress in erroneous call blocking by voice service providers. These, in particular, are the responsibility of the terminating voice service provider.

  • Notifications –Terminating VSPs must immediately notify users that a call has been blocked via SIP (Session Initiation Protocol) or ISUP (ISDN User Part) code.
  • Disclose Blocked Calls – Terminating VSPs must provide a list of opt-in or opt-out blocked calls to subscribers.
  • Disputing Blocks – Disputes filed for erroneously blocked calls must receive a status update within 24 hours of the filing.
  • Single Point of Contact – VSPs must have a clear point of contact displayed on their website to handle blocking disputes.
  • Decline for Call Labeling Redress – The FCC declined to extend the above measures for call labeling provided by VSPs.

While the FCC did provide an outline on how to handle call blocking redress issues, these do not extend to call labeling. This means that it may be more difficult to redress call labeling issues than it is for call blocking, which could prove detrimental for legitimate businesses that fall prey to caller ID spoofing.

Proposal To Implement Best Practices for Redress Requests

USTelecom laid out its recommendation on standards for addressing call blocking and labeling redress requests in August 2021. While most redress requests are handled within hours of submission, some may take longer to investigate and resolve. As such, voice service providers and analytics engine partners should aim to finalize 95% of redress requests within two business days.

Consequently, VSPs should resolve the remaining 5% of redress requests in a timely manner. However, each circumstance is different. Requests in this group must be addressed according to the FCC mandate for VSP blocking redress.

If a redress request cannot be adequately resolved within the two-business-day period, voice services providers must keep the requesting individual or business updated on the request's status. No matter the circumstance, all voice services providers must provide all initial status updates within 24 hours of the party’s redress request, in accordance with the FCC’s recent order.

Call Blocking Notifications and Rules Updates

The FCC's requirement for call blocking notifications was scheduled for January 2022. However, USTelecom filed a petition to update for reconsideration of call blocking notifications. The main disputes in USTelecom’s petition include whether these notifications should be issued using the SIP 607/608 code or allow voice services providers to use flexible methods of relaying this information.

Not all telecommunications providers are entirely on board with the FCC’s requirements without some modifications. In fact, only three voice services providers and telecommunications agencies want the order to be enforced immediately without further delay.

VSPs Debate Delay in Call Blocking Notifications

The entities opposed to delaying these call blocking notifications rules are:

  • Ad Hoc Telecom Users Committee
  • INCOMPAS, Cloud Communications Alliance
  • ABA Joint Trades

On the other hand, many more VSPs oppose the order’s strict enforcement at present. Currently, the order’s call blocking notifications rules are tough to implement. Notably, many of these VSPs are some of the telecommunications industry’s largest providers.

Voice services providers and telecom agencies in favor of delaying the FCC’s call blocking notifications rules include:

  • USTelecom
  • Voice on the Net Coalition
  • Lumen
  • NCTA—The Internet & Television Association
  • Verizon
  • Somos
  • CTIA
  • National Opinion Research Center
  • Transaction Network Services

Request For Flexibility in Call Blocking Notifications

Of the VSPs disputing the order’s rules for call blocking notifications, some of the reasons provided include:

  • Allowing VSPs the freedom to choose the proper labeling code and call blocking notifications method to alert affected parties.
  • The FCC’s order is attempting to address problems in an industry that is constantly evolving. In essence, the order itself is reliant on standards that have not yet come to fruition.
  • Legitimate businesses have been adversely affected by the implementation of call blocking standards.
  • Notifying affected parties should only be mandatory for “analytics-based blocking.”
  • Fear of inadvertently supplying robocallers with the very means necessary to bypass the call blocking efforts.

Of course, these voice services providers do not dispute the necessity to provide call blocking notifications. Moreover, they all agree that the required notification methods should be flexible and fluid.

How Caller ID Reputation Can Help

Receiving call-blocking notifications might sound like a scary prospect, but not knowing the status of your phone numbers is even scarier. Protecting your numbers and, ultimately, your business’s reputation, takes vigilance.

You can monitor your numbers and perform real-time checks to see how your caller ID appears to your customers. Furthermore, you can determine if your customers are receiving your calls at all.

Caller ID Reputation’s service, Device Cloud, tests your number during actual live calls. Know where you stand in this uncertain realm of call verification and call blocking notifications.

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Caller ID Reputation Benefits