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i3forum Shares Recommendations With The FCC On Its Proposed Rulemaking To Fight Against Robocalling

Writing on behalf of the international wholesale carrier community, i3forum requests that the FCC considers the complexities for gateway providers and offers additional tools and incentives.

i3forum, a not-for-profit industry body enabling and accelerating transformation across the carrier ecosystem, has filed comments with the Federal Communications Commission (FCC) on its proposed rulemaking to fight against robocalling. i3forum fully supports the FCC’s continuing efforts to eliminate robocalling, but requests that it takes into account the complexity of the international telecommunications ecosystem.

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The FCC’s Further Notice proposes rules that would place obligations on gateway providers to assist in combatting foreign-originated illegal robocalls. Gateway providers are at the end of a long and unpredictable chain of carriers that play a role in transporting foreign-originated calls to recipients in the United States. Due to this, they often lack the necessary information to mitigate robocalling using the procedures proposed in the Further Notice.

“i3forum supports the FCC’s goal of “eliminating the scourge of robocalling” and agrees that gateway providers should lend a hand in the fight against illegal robocalls originating abroad,” said Philippe Millet, Chairman at i3forum. “However, the FCC could help to reduce the volume of illegal traffic coming into the U.S. by equipping gateway providers with additional tools to identify problematic traffic, rather than imposing unrealistic obligations. We believe the FCC should create incentives for gateway providers to use such tools, and base its decisions on the realistic abilities of providers to meet the proposed rules.”

Some of i3forum’s main comments include:

  • The Commission should permit, but not require, gateway providers to authenticate caller ID information using STIR/SHAKEN.


  • The Commission should not impose “know your customer” requirements on gateway providers.
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  • The Commission should consider alternative robocall mitigation strategies, such as requiring gateway providers to impose an additional charge for receiving calls (even if the calls are not completed) that meet certain parameters associated with illegal robocalling. The charges would eventually flow back to the fraudulent call initiator, thereby discouraging continued illegal conduct.


  • i3forum urges the Commission to focus on providing gateway providers with additional tools to identify potentially problematic traffic (as opposed to asking providers to identify “bad actor” customers) and to provide incentives for gateway providers to use these tools.

“While gateway providers are committed to helping the FCC in its ongoing battle against illegal robocalls, the FCC should be mindful of their limited ability to meet certain proposed obligations,” added Millet. “Our aim is to put forward recommendations to help the FCC consider efficient robocall mitigation strategies that are consistent with carriers’ capabilities and can be implemented across the industry.


i3forum is a not-for-profit industry body that brings together the international Carrier ecosystem to enable and accelerate transformation. Its members promote industrywide collaboration with an open and inclusive model focused on enabling success in a changing market. i3forum decides the challenges and topics to address based on what will accelerate transformation and create real benefits for members and the entire telecommunications ecosystem. The members develop and curate practical recommendations and best practice for adopting and delivering new technologies, solutions and business models with the ultimate goal of having a positive and lasting impact on the telecommunications industry.

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