July 13, 2020

Volume X, Number 195

July 13, 2020

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July 10, 2020

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FCC Enforcement Bureau Seeks Traceback Consortium Letters of Intent

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.

© Copyright 2020 Squire Patton Boggs (US) LLPNational Law Review, Volume X, Number 111


About this Author

Paul Besozzi Telecommunications Attorney Squire Patton Boggs Washington DC
Senior Partner

Paul Besozzi concentrates his practice in the wireless, broadband and emerging technology areas. His extensive experience of more than 30 years in the telecommunications field includes regulatory, transactional, legislative and litigation matters for clients ranging from wireless service and infrastructure providers to resellers of long-distance service, including cellular, personal communications services, specialized mobile radio, point-to-point microwave, advanced wireless services and other emerging wireless technologies.

Paul represents clients before the federal and state...