INCOMPAS last week filed comments
in the FCC's second FNPRM on potential mechanisms to address the problem of unwanted robocalls to reassigned telephone numbers. The FCC sought comments on the development of a single, FCC-designated reassigned numbers database, as well as proposals to require or allow service providers to voluntarily use commercial data aggregators to report reassigned number information. These proposals would allow callers to "discover potential reassignments before they occur."
Based on the prohibitive costs to service providers, together with the speculative use and ultimate value, INCOMPAS urged the Commission to reject any proposal that would require service providers to participate in a reassigned numbers database. Instead, INCOMPAS renewed CTIA's appeal for the Commission to conduct "a comprehensive cost-benefit analysis to evaluate the complex financial, operational and technical issues" of the reassigned number database proposal.
INCOMPAS noted that "given the significant investment that a service provider would have to make to participate in a reassigned number solution," service providers should be compensated for all of their costs of reporting information either to a single database or to data aggregators should the Commission proceed. "It would be a sound policy for such costs to be borne by robocallers accessing the database seeking comprehensive and timely information on reassigned numbers," INCOMPAS suggested.