While the Commission has undertaken several efforts to mitigate scam robocalls over the last twenty years, in particular since the TRACED Act, the number of illegal robocalls, as well as estimated consumer losses from these calls, continues to grow. We urge the Commission to change the incentive structures that encourage providers to facilitate illegal call traffic and take aggressive action to eliminate these dangerous calls.
Specifically, if it is to effectively eradicate illegal calls, Electronic Privacy Information Center (EPIC) and the National Consumer Law Center, on behalf of its low-income clients, recommend that the Commission:
- Require telecommunications providers to achieve effective mitigation outcomes (not merely to
take reasonable steps), and hold providers strictly liable for any robocall-related misuse of
numbering resources that they facilitate by providing access to those numbering resources.
- Automatically and quickly suspend high-risk providers from the robocall mitigation database
(RMD) if they receive a third traceback request within twelve months; and automatically and
quickly suspend any provider who does not adequately respond to traceback requests, who is
non-compliant with paying fines or forfeitures, whose management is affiliated with known
offenders, or who otherwise evades or fail to comply with Commission rules or orders.
- Impose licensing and bonding requirements on non-facilities-based providers, so that the
Commission can a) easily collect forfeitures and fines from bad actors, and b) effectively
exclude known bad actors.
- Make traceback information public, so more stakeholders can more easily