TCPAWorld has previously reported on the Federal Communications Commission’s (FCC) efforts to implement Section 13(d) of the Pallone-Thune TRACED Act requiring the establishment of a single consortium that conducts private-led efforts to trace back the origin of suspected unlawful robocalls.
In accordance with the agency’s recently adopted rules, the FCC Enforcement Bureau (Bureau) has now required “interested consortia to provide Letters of Intent in accordance with the Commission’s updated rules and the discussion of the statutory requirements and registration process found” in the rules.
To that end, any consortium must: “(1) demonstrate that it is a neutral third party; (2) demonstrate that it is competent to manage the private-led traceback efforts; (3) include its written best practices, and an explanation thereof, regarding management of its traceback efforts and regarding providers of voice services’ participation in the consortium’s traceback efforts; (4) certify that, consistent with section 222(d)(2) of the Communications Act, the consortium’s efforts will focus on fraudulent, abusive, or unlawful traffic; and (5) certify that the consortium has notified the Commission that it intends to conduct traceback efforts in advance of registration as the single consortium.”
The Letter must also contain “a certification that, if selected to be the registered consortium, the consortium will remain in compliance with the statutory requirements; conduct an annual review for compliance; and promptly notify the Commission of any changes that reasonably bear on its certification.”
The Letters of Intent must be submitted electronically in EB Docket No. 20-22 by no later than May 21, 2020, and will be available for public comment. Public comments are due no later than June 5, 2020.