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May 01, 2017

FCC Starts with Low Hanging Fruit

Path to Implementing Trump-Era Deregulatory Agenda

Jonathan Marashlian

Federal Communications Commission (FCC) Chairman Ajit Pai endorsed two major policy initiatives last week seeking to reduce international reporting requirements and disrupt illegal robocalling.  The release of the new Notices of Proposed Rulemaking signals to industry observers that the period of transition at the FCC has officially come to an end, and the new Chairman is ready to implement a new deregulatory agenda.
A Notice of Proposed Rulemaking invites industry participants with interests in the proposed regulatory or deregulatory action to submit comments in support of or in opposition to the proposed rule change. 


Eliminate International Traffic and Revenue Reporting Requirements

Providers of international telecommunications services are required to file annual reports with the FCC detailing their traffic and revenue for international voice services, international private line services, and international miscellaneous services.  But as the FCC explained, “as the international telecommunications sector has liberalized and competition has grown,” the underlying purpose of these reports – to monitor settlement rates – has become obsolete.  The FCC proposes to eliminate the Traffic and Revenue Reporting Requirement.


Streamline Circuit Capacity Reporting Requirement

Providers of international telecommunications services are also required to file annual reports identifying submarine cable, satellite, and terrestrial capacity between the U.S. and foreign countries.  The FCC uses this data to analyze whether U.S. – international communications are competitive and secure.  The FCC seeks comments on streamlining these reports and reducing burdens on those subject to the reporting requirements.


Reduce Clearly-Fake Robocalls

The FCC announced a series of actions to address the agency’s top consumer complaint: robocalls.  The FCC estimates that U.S. consumers receive 2.4 billion robocalls each month.  The FCC’s new Notice of Proposed Rulemaking seeks to set policies that distinguish “clearly-fake” robocalls and allow carriers to block those calls.  The FCC’s proposal is permissive rather than restrictive, allowing carriers to block calls without imposing any new restrictions or regulations on companies initiating robocalls.
“Not only are unwanted robocalls intrusive and irritating, but they are also frequently employed to scam our most vulnerable populations, like elderly Americans, out of their hard-earned dollars,” Pai wrote in support of the action.
The FCC’s Notice endorses a policy that would allow carriers to block calls from numbers that were never meant to dial out, such as 1-800 customer service numbers.  The policy also allows call blocking when a phone number cannot possibly be valid, for example, if the number is unassigned, the area code does not exist, or the phone number is the wrong number of digits.  The FCC’s notice also seeks industry and consumer input on addressing and decreasing spam or scam calls originating from overseas.
If you have questions on how your business might be impacted by these proposed rules, or for assistance with filing comments in the pending rulemaking proceedings, please contact Jonathan S. Marashlian at 703-714-1313 or


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