The FCC Told Every Carrier in America to Block a Student Loan Robocall Operation

On August 24, 2022, President Biden announced student loan forgiveness. By October, the FCC said one operation appeared responsible for about 40 percent of all student loan robocalls reaching consumers that month. And it all ran through one originating carrier.

So what happened?

On November 10, 2022, the FCC's Enforcement Bureau sent a cease-and-desist letter to Fawaz Saleem, CEO of Urth Access, LLC. The same day it put out a public notice telling every U.S. voice service provider they could block Urth Access traffic without liability.

The USTelecom Industry Traceback Group had identified Urth Access as the originating provider for substantial volumes of apparently unlawful student loan robocalls. The letter gave the company three jobs:

• Investigate and mitigate the traffic right away.
• Report its mitigation steps within 48 hours.
• Explain within 14 days how it would keep customers from sending illegal robocalls.

Urth Access never responded.

So on December 8, 2022, the FCC issued a follow-up order. It directed all U.S.-based providers to mitigate traffic from what it called the "Student Loan Robocall Operation." That group included Urth Access, Fire Data LLC, US Acquisitions LLC, Dawood & Dawood, Dawood and Company, their individual associates and associated entities.

Here's the thing ...

The order didn't stop at the carrier. It named people.

The FCC said the same people who claimed to be Urth Access "customers" were also tied to Urth Access itself. According to the order, those people registered the customer websites through the same domain registrar. One person, Catherine McCormick, was listed as the incorporator of Fire Data LLC (formerly Sales Data Pro LLC). She was also listed as CEO of Global Lynks LLC, which had already gotten its own FCC cease-and-desist letter in July 2022 over auto warranty robocalls.

The FCC said the operation appeared responsible for millions of student loan robocalls, citing YouMail data for the 40 percent figure. It added that many of the same players also appeared tied to auto warranty and health insurance telemarketing calls. The calls were prerecorded and apparently made without consent, which would violate the Telephone Consumer Protection Act (TCPA).

The order also gave carriers a warning. If a provider got the order and kept carrying this traffic without investigating and reporting, the FCC could treat it as knowingly and willfully transmitting unlawful robocalls.

Why should you care?

Because this is the playbook. Hot news topic, fresh robocall campaign, small originating carrier, quick letter, quick block order. The FCC moved from letter to block order in less than a month.

If you buy or sell voice routes, you're on the hook for who's on your network. "My customer did it" doesn't work when your customer and your company look like the same people.

What to do this week

• Know your upstream customers. Who owns them? Who registered their websites?
• Answer every traceback. Silence is what got Urth Access blocked.
• Watch headline-driven campaigns. When the news says "forgiveness," expect a wave of junk.

Look, a cease-and-desist letter from the FCC is a gift. Respond to it. That's it.