Student Loan and Amazon Robocalls Landed Two Carriers on the FCC's Warning List

On January 11, 2023, the FCC's Enforcement Bureau sent two of them. One was addressed to SIPphony LLC, based in Mesa, Arizona. The other went to Vultik Inc. in Casper, Wyoming.

So what happened?

According to the FCC and the USTelecom Industry Traceback Group, illegal, prerecorded robocalls had been traced back to the companies as the originating provider.

The calls were flagged by customers of YouMail as robocalls made to wireless numbers without consent. That's a Telephone Consumer Protection Act (TCPA) problem under 47 U.S.C. 227(b).

Here's what the attachments to the letters show:

• Vultik: The tracebacks covered calls investigated between June 1 and October 19, 2022. The listed calls carried descriptions like "StudentLoan-ForgivenessCenter" and "Amazon-AuthorizeOrder." The customers named in the attachment include Right Communications and Marketing and Admy Telecom Inc.
• SIPphony: The tracebacks covered calls investigated between October 11 and November 15, 2022. The listed calls were labeled "StudentLoan-Forgiveness-P2," and the customer named was Direct Connect.

The 48 hour clock

Each letter told the company to:

1. Promptly investigate the calls listed in the attachment.
2. Effectively mitigate the traffic by finding the source and cutting it off.
3. Put safeguards in place so customers can't use the network for illegal calls.
4. Tell the FCC and the Traceback Consortium within 48 hours what it did.
5. Within 14 days, explain how it would keep new or renewing customers from doing the same thing, with a sworn declaration.

Miss those steps, and downstream carriers could start blocking all of the company's traffic. The FCC also warned it could begin proceedings to pull the company out of the Robocall Mitigation Database. That would mean other providers couldn't take its calls directly at all.

Why should you care?

The FCC's press release that day said more than 20 providers had gotten warning letters by then. Almost all of them either showed the robocall traffic was cut off or told the FCC they were shutting down. Read that again. Shutting down.

FCC Chairwoman Jessica Rosenworcel put it this way: "Scam robocalls are more than just a nuisance, they waste our time and resources and destroy trust in our communications networks."

And notice the pattern. Student loan forgiveness was big news in late 2022. Scammers love a headline. If your customers suddenly start pushing traffic about whatever's on the news, ask questions. Am I right?

What to do this week

• Pull your traceback history. If the Traceback Consortium keeps asking about the same customer, you already have your answer.
• Set up a 48 hour playbook. Who reads the letter? Who cuts the traffic? Who signs the response?
• Vet who you're carrying. "They're just another carrier" won't save you if the calls are illegal.

That's it. Respond fast and keep the junk off your network.