FCC’S ENFORCEMENT BUREAU REQUESTS INFORMATION ON THE STATUS OF PRIVATE-LED TRACEBACK EFFORTS OF SUSPECTED UNLAWFUL ROBOCALLS

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Section 13(c) of the Pallone-Thune TRACED ACT required the Federal Communications Commission’s (FCC) Enforcement Bureau (Bureau), not later than 210 days after date of enactment (i.e., by July 27, 2020) and “annually thereafter to issue a notice seeking comment on private-led efforts to trace back the source of suspected unlawful robocalls, and not later than one year after that date and annually thereafter to issue a report on the status of such private-led efforts.”

On July 20, 2021, the Bureau released a Public Notice

(https://docs.fcc.gov/public/attachments/DA-21-864A1.pdf ) that “requests voice service providers and the registered consortium, USTelecom’s Industry Traceback Group (Traceback Group), to submit any information necessary for the Commission’s annual report on the state of private led efforts to trace back the origin of suspected unlawful robocalls.”

Each annual report must contain at least the following information

“1. A description of private-led efforts to trace back the origin of suspected unlawful robocalls by the registered consortium and the actions taken by the registered consortium to coordinate with the Commission.

2. A list of voice service providers identified by the registered consortium that participated in private-led efforts to trace back the origin of suspected unlawful robocalls through the registered consortium.

3. A list of each voice service provider that received a request from the registered consortium to participate in private led efforts to trace back the origin of suspected unlawful robocalls and refused to participate, as identified by the registered consortium.

4. The reason, if any, each voice service provider identified by the registered consortium provided for not participating in private-led efforts to trace back the origin of suspected unlawful robocalls.

5. A description of how the Commission may use the information provided to the Commission by voice service providers or the registered consortium that have participated in private-led efforts to trace back the origin of suspected unlawful robocalls in the enforcement efforts by the Commission.”

The reporting period for the Bureau’s request for information is from July 27, 2021 to October 31, 2021. Submissions are due by November 15, 2021.

 

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Published by Eric J. Troutman

The Czar of TCPAWorld Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems. Eric has built a national litigation practice based upon deep experience, rigorous analysis and extraordinary responsiveness. Eric and his team feel equally at home litigating multibillion dollar telecommunications class actions in federal court as they do developing and executing national litigation strategies for institutions facing an onslaught of individual TCPA matters. They thrive in each of these roles – delivering consistently excellent results – while never losing sight of the client experience. While many firms now tout TCPA expertise, Eric has been there from the beginning. He built one of the country’s first TCPA-only defense teams and began serving as national TCPA counsel for his clients nearly a decade ago. This perspective allows him to swiftly develop the right litigation strategies for dealing with recurring problems, without wasting time on tactics that are bound to fail. Eric’s rich historical perspective and encyclopedic knowledge of the TCPA landscape also make him an invaluable resource to institutional compliance teams struggling to comply with the shifting regulatory landscape. No task is too small – or too big. Indeed, Eric and his team have helped build TCPA-compliant systems and processes for some of the largest and most complex corporate entities in the country. He commonly works with in-house compliance counsel to build and implement enterprise and business-line specific TCPA solutions, performs TCPA audits and drafts and reviews proposed TCPA policies and procedures. He and his team also have the technical expertise necessary to assist call centers seeking to develop TCPA-resistant call path architecture or to modify existing telephony and software integration to better insulate from potential TCPA exposure. Eric has built a reputation for thought leadership. An avid blogger and speaker, he has been at the forefront of the industry’s effort to push for clarity and a return to sanity for the TCPA for years. He was selected to advocate for the financial services industry on important TCPA issues before the Federal Communications Commission and co-authored the nation’s only comprehensive practice guide on TCPA defense. In his spare time, Eric leads defense teams representing banks and other financial services companies in consumer finance litigation matters. He has experience representing clients in UCC, TILA, RESPA FCRA, CCRA, CLRA, FDCPA, RFDCPA and FCCPA claims, as well as in fraud and bank operations issues.

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