As of June 30, 2021, all service providers must meet the new Traced Act’s specific compliance requirements. Providers must make provisions for their adherence, accounting for particular concerns regarding their responsibility to minimize illegal robocalls while delivering ongoing service for their customers.

1. Use STIR-SHAKEN or robocall mitigation on every call originated with U.S. NANP calling numbers.

Providers must use STIR-SHAKEN on every call terminating in the U.S. The FCC provided a deadline extension to 2023 for small voice service providers with fewer than 100,000 subscriber lines, only to implement STIR-SHAKEN.

If small voice providers seek an extension, they must have robocall mitigation for every number without STIR-SHAKEN and must state the specifics of their program and their adherence to the other four requirements.

Even if you qualify for an extension as a small voice provider, there are benefits to adopting STIR-SHAKEN by the June 30 deadline. They include better call completion for your business clients and improved customer satisfaction with verified call delivery.

You may consider doing both STIR-SHAKEN and a robocall mitigation program, as the FCC will require one if illegal robocalls originate on your network. Having both in place by the deadline can save you hassle and stress later.

2. File your Robocall Mitigation Certification in the new FCC Robocall Mitigation Database.

Once a service provider opts for STIR-SHAKEN, a robocall mitigation program, or both, then they have to file a certification with the FCC. All certificates need detailed descriptions of how that service provider will reduce the incidence of illegal robocalls.

Following the certificate’s filing, the provider must follow through on the actions described.

Providers have to consider what steps they can take that will significantly reduce illegal robocalls. They also have to implement those steps across their network by the deadline and describe them in sufficient detail in the certification. STIR-SHAKEN and robocall experts can help providers with articulating and implementing effective mitigation strategies.

3. Block calls on your network with U.S. NANP numbers that don’t have Robocall Mitigation Database certifications on file.

The call blocking requirement puts the onus on intermediate and terminating providers to enforce the STIR-SHAKEN specification. It doesn’t cause a real-time check-and-end for every call through the provider’s network, but a periodic review of the Robocall Mitigation Database to ensure upstream providers have filed their certifications.

Even foreign service providers must file a certification since the TRACED Act applies to all calls ending in the U.S. Foreign service providers may not be aware of the new regulations, so common circumstances could cause termination of valid calls, such as:

• Travelers overseas with U.S. NANP calling numbers, roaming on a foreign provider network
• A U.S. company using overseas call centers for their services from U.S. NANP numbers

The FCC is reviewing a petition for partial reconsideration regarding this rule.

To prepare your customers, make a list of all your upstream providers, including those overseas, and let them know about the new requirement and ask if they’ll be able to comply. Evaluate if your robocall mitigation program can take on responsibility for all your upstream providers.

4. Provide full, prompt cooperation with traceback requests for illegal robocalls.

Many providers aren’t aware of what a robocall traceback request is. It’s imperative to train staff now so they’re able to respond fully and rapidly to TRACED Act requests by the June 30 deadline.

Suppose a service provider doesn’t respond to a traceback request from the Industry Traceback Group (ITG). In that case, the ITG can label them as non-cooperative. With escalation, the FCC can get involved and direct other carriers to end traffic with non-cooperative providers.

To avoid a non-cooperative designation and potential escalation, appoint dedicated staff to handle all traceback requests. Train all staff to recognize and prioritize these requests.

Work with Prescott-Martini to implement STIR-SHAKEN and prepare your robocall mitigation program by the TRACED Act deadline.

Our team has over 150 years of telecommunications experience at your disposal to meet the four TRACED Act requirements by the June 30 deadline. Whether you’re implementing STIR-SHAKEN, using a robocall mitigation program, or both, we’ll help you adopt new regulations with ease.

Prescott-Martini can keep your company running smoothly while adhering to the TRACED Act. Contact us today.