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i3forum shares recommendations with the FCC on its proposed rulemaking to fight against robocalling

robocalling

i3forum, a not-for-profit firm that enables and accelerates change in the carrier ecosystem, has filed comments with the Federal Communications Commission (FCC) on its proposed rule to fight against robocalling. i3forum supports the FCC’s continued efforts to stop robocalling entirely, but requests that it consider the complexity of the international telecommunications ecosystem.

Further Notice from the FCC proposes rules that would put an obligation on gateway providers to help combat illegal foreign-based illegal robocalls.

At the end of unpredictable and long chain of carriers are gateway providers that play an important role in transporting foreign-based calls a recipient in the United States. Because of this, they generally lack the information to stop robocalling using the steps proposed in the Further Notice.

“i3forum supports the FCC’s goal of “eliminating the scourge of robocalling” and agrees that gateway providers should lend a hand in the fight against illegal robocalls originating abroad,” said Philippe Millet, Chairman at i3forum.

“However, the FCC could help to reduce the volume of illegal traffic coming into the U.S. by equipping gateway providers with additional tools to identify problematic traffic, rather than imposing unrealistic obligations. We believe the FCC should create incentives for gateway providers to use such tools, and base its decisions on the realistic abilities of providers to meet the proposed rules,” he added.

Some of the main comments of i3forum include:

  • The Commission must allow gateway providers to authenticate caller ID information using STIR/SHAKEN, but is not required to.
  • The Commission must not impose “know your customer” requirements on gateway providers.
  • The Commission must consider alternative robocall mitigation strategies, for example requiring gateway providers to charge an additional fee for receiving calls (even if the call is not completed) that meet certain criteria associated with illegal robocalling. The charges will eventually go back to the fraudulent call initiator, thereby discouraging continued illegal conduct.
  • i3forum encourages the Commission to concentrate on offering additional tools to gateway providers to identify potentially problematic traffic (as opposed to asking providers to identify “bad actor” customers) and to offer incentives for using these tools to the gateway providers.

“While gateway providers are committed to helping the FCC in its ongoing battle against illegal robocalls, the FCC should be mindful of their limited ability to meet certain proposed obligations,” added Millet. “Our aim is to put forward recommendations to help the FCC consider efficient robocall mitigation strategies that are consistent with carriers’ capabilities and can be implemented across the industry.”

Gateway providers share the goal of FCC goal of mitigating illegal robocalls from getting into their networks – they just need the tools and guidance to do so in today’s complex international calling industry.

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