The Federal Communications Commission (“FCC” or “Commission”) Friday issued a Report & Order and Further Notice of Proposed Rulemaking that requires mobile wireless carriers to implement new robotext mitigation measures and seeks comments on additional proposed robotext rules. The compliance deadline for the new regulations is six months after the document is published in the Federal Register. The comment deadline for the proposed rules is 30 days after such publication and the reply comment deadline is 60 days after publication.

Specifically, the new rules require mobile carriers to block, at the network level, texts from numbers on a “reasonable Do-Not-Originate (DNO) list” which includes numbers that purport to be from invalid, unallocated, or unused numbers, and numbers which subscribers have requested be blocked. The FCC also requires mobile providers to maintain a single point of contact for texters to report erroneously blocked texts.

The FCC seeks comment on the following proposals:

• whether terminating mobile wireless providers should be required to investigate and potentially block texts from a sender after they are on notice from the FCC that the sender is transmitting suspected illegal texts;
• whether there are plausible solutions other than requiring caller ID authentication measures to combat spoofing;
• whether the National Do-Not-Call Registry protections should apply to text messages as well as voice calls;
• whether the FCC should ban the practice of obtaining a single consumer consent as grounds for delivering calls and text messages from multiple marketers on subjects beyond the scope of the original consent; and
• how these proposals can promote or inhibit diversity and accessibility.

NEED HELP WITH ROBOCALL MITIGATION, COMPLIANCE AND LITIGATION SUPPORT/DEFENSE AGAINST BUSINESS & LEGAL CHALLENGES?

The CommLaw Group Can Help!

Given the complexity and evolving nature of the FCC’s rules, regulations and industry policies & procedures around Robocall Mitigation and Compliance issues (e.g., Stir/Shaken, TRACED Act, FCC Rules & Regulations, US Telecom Industry group, ATIS, NECA, VoIP Numbering Waivers, Know Your Customer and the private sector ecosystem), as well as the increased risk of business disputes, consumer protection enforcement by state attorneys general, and even civil litigation, and anticipating the potential torrent of client questions and concerns, The CommLaw Group formed a “Robocall Mitigation Response Team” to help clients (old and new) tackle their unique responsibilities.

CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S COMPLIANCE EFFORTS
Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com
Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com
Ron Quirk – Tel: 703-714-1305 / E-mail: req@CommLawGroup.com