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i3forum Shares Recommendations with the FCC on Its Proposed Rulemaking to Fight Against Robocalling

On behalf of the international wholesale carrier community, the i3forum has filed comments with the Federal Communications Commission (FCC) on its proposed rulemaking to fight against robocalling. Its Further Notice proposes rules that would place obligations on gateway providers to assist in combatting foreign originated illegal robocalls.

We fully support the Commission’s continuing efforts to eliminate robocalling. As the Commission considers its next steps, i3forum requests that it takes into account the complexity of the international telecommunications ecosystem. We hope that the FCC will base its decisions on realistic expectations regarding the ability of gateway providers to meet the obligations proposed in the Further Notice.

The FCC can help 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, and should create incentives for gateway providers to use the tools.

Some of our main points include:

  • The Commission should permit, but not require, gateway providers to authenticate caller ID information using STIR/SHAKEN.
  • The Commission should not impose “know your customer” requirements on gateway providers.
  • The Commission should consider alternative robocall mitigation strategies, such as requiring gateway providers to impose an additional charge for receiving calls (even if the calls are not completed) that meet certain parameters associated with illegal robocalling. The charges would eventually flow back to the fraudulent call initiator, thereby discouraging continued illegal conduct.
  • i3forum urges the Commission to focus on providing gateway providers with additional tools to identify potentially problematic traffic (as opposed to asking providers to identify “bad actor” customers) and to provide incentives for gateway providers to use these tools.

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

You can read our comments in full by clicking the button below.

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