IS THIS EVEN LEGAL?: Foreign Trade Organizaton the Mobile Ecosystem Forum Submits “Comment” On FCC KYC NPRM– But It Looks Like ChatGPT Slop

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The Mobile Ecosystem Forum–some cadre of European telecom knuckleheads I call the Mobile Brotherhood– just submitted an unsigned “comment” on the FCC’s new KYC NPRM that reads as if ChatGPT wrote it.

Now I always try to be positive and say nice things about people/organizations but this is really the most bizarre submission I have ever seen to the FCC from a trade organization.

The authors here– if there were any–should really be ashamed and every member of this organization should be asking itself what they’re doing.

Here’s what I mean.

Rather than take a clear and identifiable position on any issue the “comment” simply synthesizes ad regurgitates back to the Commission its own thoughts about the opportunities and challenges posed by the NPRM.

Example:

On  “Upstream Vetting” the comment states only:

Opportunity: Formalising obligations to monitor and vet upstream providers closes loopholes where illegal traffic enters through lax intermediate networks, improving overall supply chain accountability.

Ummm, yeah that’s what the Commission said. It goes on:

Challenge: The practical application of vetting upstream providers is complex, particularly concerning specific documentation requirements. Mandating the provision of documents such as US state business registry filings is highly problematic for international providers. Many legitimate foreign entities do not possess these specific corporate structures or equivalent documentation. Vetting requirements must remain flexible enough to accommodate international corporate records to avoid disrupting global traffic flows.

What does this even mean?

I guess MEF wants traffic from companies that aren’t really companies to come flowing in to the US? Guess I shouldn’t be surprised when this FOREIGN organization starts trying to INFLUENCE U.S. telecom policy.

They give no examples and don’t try to build out a use case. Just suggest some foreign entities might want access to our networks and we should just let them through without verification because–hey, maybe its hard to get an I.D. card in Belarus, you know what I’m saying?

Anyway this “comment” is kind of a mess. Not surprised no one signed it.

If you’re a MEF member– why?

You can read the entire thing here: Mobile Ecosystem

Chat soon.

 

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Published by Eric "Czar" 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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