North American Numbering Plan

The FCC continues its efforts to improve rural call completion, teeing up a draft Fourth Report and Order (“Order”) that would adopt new service quality standards for intermediate providers (i.e. entities that carry, but do not originate or terminate calls) for consideration at its March 15, 2019 Open Meeting. The Order, which would further implement the Rural Call Quality and Reliability Act of 2017 (“RCC Act”), proposes intermediate provider service quality standards and related enforcement procedures, and sunsets existing call data recording and retention rules for covered providers. The Order also would deny two pending Petitions for Reconsideration of previous rural call completion orders. Although the proposed service quality standards would not take effect until the later of six months after the Order is released or 30 days after it is published in the Federal Register, intermediate providers will want to begin familiarizing themselves with the proposed new rules now in light of the significant potential enforcement penalties for noncompliance.

Continue Reading FCC Set to Adopt Rural Call Completion Service Quality Standards

With speculation running rampant that Chairman Pai intends to bring a remand order from ACA International v. FCC in January 2019, the FCC took a related step to reduce misdirected calls.  At the December Open Meeting, the FCC approved a Second Report and Order (“R&O”) to create a single, nationwide database for reporting number reassignments that will allow callers to verify whether a phone number was permanently disconnected before calling the number. The item is meant to reduce “wrong number” calls to mobile phones, i.e., where a caller has a legitimate reason for trying to reach a consumer but doesn’t realize that the number they have has been reassigned to someone else. The new rule would help eliminate a scenario where the new holder of the number receives an unwanted call and the prior holder never receives the call intended for them. The R&O is part of a broader effort by the FCC to address and stem the volume of unwanted phone calls in the United States.

Continue Reading In a Prelude to its TCPA Ruling, the FCC Votes to Create a Database to Identify Reassigned Numbers