Over the past week, there have been two notable developments in the world of voice service providers (VSPs) and their customers. First, the Federal Communications Commission put three VSPs on notice that if they continued to originate illegal robocalls on their networks, the FCC would instruct carriers to block all of their calls. The warning came in the form of Cease-and-Desist Letters and was the result of information provided by the Traceback Consortium, which is administered through USTelecom. These actions emphasize the importance of responding to a Traceback Request within 48 hours.
The second development was a comment made at SIPNOC 2022 during a public presentation given by the Federal Trade Commission and other regulators, including the Vermont Attorney General, who said that an Assurance of Voluntary Compliance (AVC) from a recent enforcement action against a VSP encompasses the requirements for VSPs “Know Your Customer” (KYC) obligations. The list is over 20 items long. Some items can be obtained from the customer, but others require research through various publicly available services.
A VSP is required to engage in a KYC process before onboarding a new customer to prevent illegal telephone calls from being initiated on its network.
You can view the “model” KYC screening practices outlined in the Vermont AVC here.
Michele is the Managing Partner at M&S and former Chief of the Ohio Attorney General’s Consumer Protection Section. Bringing more than two decades of experience in the consumer protection arena, she advises highly regulated businesses on a wide range of telemarketing, privacy, and other consumer protection matters.