Comments of The American Bankers Association, ACA International, American Association of Healthcare Administrative Management, American Financial Services Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and Student Loan Servicing Alliance to the Sixth Further Notice of Proposed Rulemaking
The Associations appreciate the opportunity to comment on the Sixth Further Notice of Proposed Rulemaking (Sixth Further Notice) in the above-captioned proceeding. In its Order on Reconsideration, issued simultaneously with the Sixth Further Notice, the Federal Communications Commission (Commission) permitted telephone companies that block calls and their analytics providers (collectively, Voice Service Providers or Providers) to use Session Initiation Protocol (SIP) Code 603 to notify the caller that its call has been blocked. Although the Commission had previously required Voice Service Providers to use only SIP Codes 607 or 608 to provide this notification as part of its earlier Fourth Report and Order, the Commission determined in the Order on Reconsideration (Order) that implementing SIP Codes 607 and 608 by the original January 1, 2022, deadline “appears infeasible” at this time.
Although implementation of SIP Codes 607 and 608 “require[s] additional time,” the Commission proposed in the Sixth Further Notice “that terminating voice service providers ultimately use only SIP Codes 607 or 608” to provide immediate notification of blocking. We agree. SIP Codes 607 and 608 represent a standardized, uniform set of response codes that are specifically designed to identify end-user blocking of unwanted calls (SIP Code 607) or blocking in the network based on reasonable analytics (SIP Code 608). To facilitate the timely transition to SIP Codes 607 and 608 and ensure compliance with the TRACED Act, the Commission should request that the Alliance for Telecommunications Industry Solutions (ATIS) submit a projected time for finalization of operational standards for these codes and request that ATIS and Voice Service Providers provide regular status reports on the finalization and implementation of the codes. In addition, the Commission should set a firm deadline for mandatory use of SIP Codes 607 and 608 to provide immediate notification of blocking.
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