Classification drives the obligations
Telecommunications compliance begins with what your service is in regulatory terms. Traditional carriers, interconnected VoIP providers, resellers, and information service providers carry different obligations at the FCC, and a product can shift categories as features are added. State utility commissions, including the New York Public Service Commission, have their own authorization and reporting regimes for some services. Classification affects, among other things, whether you contribute to the Universal Service Fund through USAC and which customer data rules apply to you. Mistakes tend to surface during an audit, a contribution review, or a dispute with an upstream carrier.
Robocalls and the traffic you carry
Voice providers have a growing set of duties aimed at illegal robocalls, including call authentication under the STIR/SHAKEN framework and a certification in the FCC's Robocall Mitigation Database. The FCC has removed providers from that database for deficient filings, after which other carriers must stop accepting their traffic, and that can halt a business quickly. Providers are also expected to vet their customers and respond to traceback requests from the industry traceback group. If you place marketing calls or send texts yourself, the Telephone Consumer Protection Act and its consent rules apply separately, and courts have read parts of that law differently. Keep your filings, customer vetting records, and traceback responses together where they can be produced on short notice.
Starting a compliance review
We usually begin with a plain description of what you sell, how calls or data move through your network, which carriers and platforms you depend on, and where your customers are. That lets us identify the federal and state registrations that apply and check them against what has actually been filed. Many smaller providers find that filings fell behind during growth; some gaps can be fixed through corrective filings, while others call for a more careful approach. Mergers, asset sales, and changes in ownership of licensed providers often need prior approval from the FCC or a state commission, so a deal can expose old problems. The first meeting typically sets priorities by asking which gaps could interrupt service soonest.
