FCC Enforcement Advisory on Combating Illegal Student Loan Robocalls

On November 3, 2022, the Enforcement Bureau released an Enforcement Advisory reminding voice service providers to combat illegal robocalls aggressively, particularly student loan robocalls, which have increased after the recent announcements regarding student loan forgiveness and payment deferments.  The Advisory reminds providers that they have an obligation to “know your customer” and also highlights their other obligations, including:

  • Permissive Call Blocking:  Providers may block all traffic from an originating or gateway provider that has received notice from the Commission and that fails to effectively mitigate illegal traffic within 48 hours or fails to implement effective measures to prevent new and renewing customers from using its network to originate illegal calls.
  • Mandatory Blocking: Gateway providers must block all identified illegal and substantially similar traffic (unless investigation determines the traffic is not illegal) when it receives notice of suspected illegal traffic from the Enforcement Bureau.
  • Robocall Mitigation: Providers must take steps to mitigate illegal traffic upon written notice of such traffic from the Enforcement Bureau. This includes, knowing its customers to prevent new and renewing customers form originating illegal calls.
  • Robocall Mitigation Database Removal: An originating or gateway provider that is unable to implement STIR/SHAKEN must submit a mitigation plan to the database.  An originating or gateway provider that knowingly or negligently transmits illegal robocalls may have its certification removed from the database.  Intermediate and terminating providers may only accept traffic from providers in the databased and that have not been delisted.

The Advisory emphasizes that “The Enforcement Bureau will vigorously enforce the Commission’s rules and obligations placed on voice service providers responsible for originating or acting as the U.S. gateway for scam student loan robocalls.  Providers should be vigilant of such scam robocalls transiting their networks and take effective mitigating measures to prevent these calls from reaching consumers.  Failure to do so may result in enforcement actions.”

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