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Stopping Illegal Robocalls Where They Start

Best Practices When Accepting Traffic From Upstream Providers

It is not unusual for one provider (the “Upstream”) to approach another provider (the “Downstream”) to carry Upstream’s calls further on the network towards the destination.

Before doing business (or continuing to do business) with a potential Upstream, the Downstream should be sufficiently satisfied that the Upstream is a legitimate operator. A law-abiding Upstream should provide, and the Downstream should critically review:

  • Full contact details including telephone, email and physical address
  • Business registration with executive names, titles and contacts
  • Website showing services offered
  • Business Credit Rating
  • Customer and trade references
  • Current registration as FCC 499A Filer and Intermediate Provider

Proactive Downstreams build the following provisions into their service agreements with Upstreams:

  • Prompt cooperation with industry traceback efforts
  • Acceptance of fees for illegal calls traced by Downstream as sourced by Upstream
  • Caller-ID values must belong to the calling party or be used with express permission of the assignee
  • Acknowledgement that details of illegal calling will be shared publicly
  • Assurance that these provisions will be imposed by Upstream on all providers further upstream

An Upstream located outside the United States should be treated as an end-user CUSTOMER rather than as a Provider. USA Caller-ID values from foreign entities should be blocked except when the Downstream has legal and financial recourse to address potential violations.