RE: Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59.
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L St. NE
Washington, DC 20554
Dear Ms. Dortch:
On October 22, 2021, representatives of the Credit Union National Association, American Bankers Association, ACA International, American Association of Healthcare Administrative Management, American Financial Services Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and American Express (“the Associations”) met telephonically with Mark Stone, Jerusha Burnett, Kristi Thornton, and Aaron Garza of the Federal Communications Commission’s (“FCC” or “the Commission”) Consumer and Governmental Affairs Bureau. During the meeting, the Associations discussed USTelecom’s Petition for Reconsideration and recent ex parte communications regarding the requirement in the Fourth Report and Order that voice service providers that block calls must notify callers of the block using SIP Codes 607 and 608 and, for TDM networks, ISUP Code 21 beginning on January 1, 2022.
The Associations respectfully urge the Commission to retain the specific notification mechanisms required by the Fourth Report and Order and listed above. In light of concerns raised by certain voice service providers that the SIP Codes will not be ready to be implemented by the January 1, 2022 deadline, we would not oppose a limited, six-month extension of the deadline, provided that the Commission receive status reports at reasonable intervals to track implementation progress. This extension would provide voice service providers with a total of 18 months to implement the requirements in the Fourth Report and Order. Extending the deadline for a maximum of six months will help alleviate concerns that providers may cease blocking unlawful calls because they cannot implement the Commission’s notification requirement by the current deadline. However, we continue to oppose elimination of the specific notification requirements required by the Fourth Report and Order and their replacement with SIP Code 603, and we urge the Commission to reject that request as contrary to the public interest.
The Associations continue to support reasonable, pro-consumer outcomes in this proceeding and appreciate that USTelecom recognizes the vital importance of notifying callers immediately that their legitimate calls are being blocked by carriers. The Associations encourage the Commission to ensure that carriers adopt SIP Codes 607 and 608 as required by the FCC’s Fourth Report and Order and that are consistent with the TRACED Act’s mandate that redress be effective and transparent.
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