MYTH: Historically, the FCC has prohibited voice providers from blocking calls. FACT: Providers have extensive…
New FCC rules took effect in 2021, putting the onus on Voice Service Providers to police the calls that they originate in order to mitigate illegal robocalling. Providers selling dialer traffic termination services are the primary source of illegal robocalls. While there are some legitimate uses of dialer traffic, most dialer traffic today is illegal. Providers choosing to offer this service need to be certain that they accept only legal traffic from legitimate customers. Providers offering conversational traffic termination need to make sure it has not been polluted with dialer traffic.
Let’s break this down.
Telephone service providers enter into contracts with each other to allow telephone calls to make their way from the origination point to the termination point. For years, these contracts have distinguished between two types of call traffic. Conversational traffic consists of conventional telephone calls dialed by a human (a home landline user or an office worker or a mobile phone subscriber). Dialer traffic refers to machine-dialed calls, which typically originate from a call center or are placed by computers playing recorded messages.
Despite extensive variability among calls within each traffic type, the two types have very distinct characteristics that have been learned from billions of calls and are fairly consistent. Conversational traffic has an average call duration (ACD) of at least three minutes and at least 20% of the calls will last longer than two minutes.
Dialer traffic (which is also referred to as call-center or short-duration or high-velocity traffic) will have an ACD of under a minute, and 90% or more of the calls will last less than 60 seconds.
Provider contracts distinguish between the two traffic types because dialer traffic is much more resource intensive on a per-call basis (since all the messaging to set up and bill for the call is amortized over far fewer call seconds). Dialer traffic is far more likely to include illegal calls and to generate more complaints. Many providers refuse to accept dialer traffic; others seek it out but charge more for it.
If the two traffic types are mixed together, it becomes difficult or impossible to tell which calls originated as which traffic type. Is a 10-second call a robocall, or a human-dialed call hanging up on voice-mail? Managing dialer traffic is much easier when it is kept separate from conversational traffic. Many providers impose penalties to deter the blending of the two.
Pharmacies have to take special precautions with certain classes of drugs. Laboratories and logistics companies have to be especially careful with specific chemicals and compounds. By the same token, phone companies need to follow special protocols regarding dialer traffic.
Customers afforded the privilege of originating dialer calls must be thoroughly vetted. The provider must thoroughly know the caller and the nature of the calls, confirm their legality, and ensure that the caller has appropriate compliance measures in place. Dialer calls must originate from a finite set of originating (caller-ID) values; the provider must verify that the caller owns or has permission to use these numbers and that they answer appropriately when called back.
Providers accepting conversational traffic must ensure that it is not contaminated by dialer calls; this is done by routine evaluation of call duration and caller-ID values in call detail records (CDRs). Anomalies demand immediate follow-up with definitive explanations. Dialer traffic is dangerous; guesses or assumptions are insufficient.
Providers that take calls from foreign sources must be particularly cautious. The worst robocalls are those that impersonate government agents or claim to represent well-known American brands. Callers use this misrepresentation to perpetrate terrible frauds, including tricking victims into giving up significant sums of money or stealing their identities. And by and large, these calls, placed by the millions every day, originate outside the USA.
A key rule for any provider to follow is to refuse to accept dialer traffic from outside the USA. There are very few legitimate cases where a foreign caller would need to use automated dialing to reach USA call recipients. Perhaps, for example, an overseas call center is working on behalf of an American organization. In such a situation, the calls should be sent via that USA-based entity which then sponsors the calls with the USA provider, on behalf of their foreign call center. Only in this way can the parties be properly vetted. These calls must not meander through one or more foreign aggregators, where they get comingled with fraud calls.
Thus, even providers that intend to accept only conversational traffic need to take extra precautions when engaging with foreign customers. They must monitor CDRs for each customer to ensure that the traffic conforms to conversational metrics. The USA provider must insist that their foreign upstreams also perform this monitoring. Foreign sources sending surreptitious dialer traffic must be terminated.
Fraudsters are constantly working to evade any roadblocks in their path. Falsehoods and deceit are in their nature. Any robocall mitigation program will need to evolve with time. Customer contracts must have the flexibility to respond to changing threats and to void confidentiality restrictions when illegal calling is suspected.