Week ending October 2, 2026 — Regulatory Watch

USTelecom filed its answer to the critics of agreement-less IP interconnection on September 30, with declarations from AT&T’s Hany Fahmy and Martin Dolly and Verizon’s Lance Lockhart, while INCOMPAS and Inteliquent took the transit-provider case to bureau staff and two commissioners’ offices. On September 30 the Commission adopted the TCPA consent-revocation order and the 911 Framework NOI. The Wireline Bureau set October 15 as the effective date for the discontinuance and network-change rules in FCC 26-19.

USTelecom puts dates on the ALIII standards

USTelecom’s letter, signed by Nirali Patel and Scott Angstreich of Kellogg Hansen and filed in WC 25-304, WC 25-208 and WC 17-97, restates the proposal: every voice provider with numbering resources makes at least one IP address available on the public internet to receive traffic on a bill-and-keep basis, and providers with 100,000 or more active numbers designate a second interconnection point off the public internet. Each provider publishes a fully qualified domain name that resolves to its receiving servers. The letter goes after Inteliquent’s estimate that ALIII would need 1.12 million agreements: “The ‘AL’ in ALIII means ‘agreement-less,’ so implementing ALIII requires no new bilateral agreements.” It says the FQDNs “are meant to be accessible only to other authorized voice service providers or authorized intermediaries,” and that interconnection between providers is separate from 911 routing, which goes to NG911 network operators under the Commission’s NG911 rules.

The schedule is in the declaration of Martin Dolly of AT&T, co-chair of the ATIS-SIP Forum IPNNI Task Force. Three documents are in progress: a profile for the interface between originating and terminating session border controllers, a discovery, routing and connectivity document, and a trust architecture and certificate management document that covers “issuance, management, validation, renewal, rekey, replacement, expiration, and revocation of ALIII mutual TLS certificates.” The first two are scheduled for letter ballot in November and publication in December 2026; the certificate document may follow about a month later. Hany Fahmy of AT&T says AT&T interconnects in IP with 28 providers, 9 of them over the public internet, which carry about 1.4 million of AT&T’s roughly 124 million busy-hour IP interconnection minutes, about 1.1 percent. Lance Lockhart of Verizon says Verizon has interconnected over the public internet since 2002, now with more than 200 carrier and wholesale customers and nearly 2.5 billion minutes in July 2026. Those links secure SIP signaling with IPsec; ALIII would use mutual TLS.

USTelecom also endorses the AT&T and Verizon interim plan: an incumbent that offers IP interconnection for all calls to its customers in a LATA, and for transit traffic, could stop offering TDM interconnection and retire its local and tandem switches there after one year’s notice to subtending carriers. On Inteliquent’s National Transit Provider model, USTelecom says “the Commission must get back into the rate-setting business.”

INCOMPAS and Inteliquent push the transit model

INCOMPAS’s Christopher Shipley, with Greg Rogers of Bandwidth, Jill Sandford of FirstLight Fiber and Bill Greenlaw of Sonic, met six WCB staff on September 25 and filed on September 29. INCOMPAS reads Verizon’s September 11 support for LATA-by-LATA forbearance as evidence that ALIII “is not technically or operationally ready to support a safe, scalable, or competitively neutral IP transition.” It lists five problems with the AT&T plan: a patchwork of LATA regimes, no answer for universal connectivity if SS7 and other TDM vendors exit before rural LATAs migrate, transit rates without oversight, unconditional Section 251 forbearance as of December 31, 2028, and 911 delivery in LATAs where the incumbent retires its TDM tandem before local PSAPs move to NG911. The attached September 1 letter estimates, from STIR/SHAKEN experience, that ALIII standards and implementation could take “approximately six years.” INCOMPAS also asks that any 251(c)(6) collocation forbearance grandfather existing arrangements.

Former commissioners Harold Furchtgott-Roth and Robert McDowell, with Tamar Finn of Cooley, met Jonathan Uriarte in Commissioner Gomez’s office and Marcus Maher in Commissioner Trusty’s office on September 24 for Inteliquent. The filing says the NTP model “can be fully deployed within a two-year window” and that USTelecom’s proposal “fails to address many details such as transport, transit, and recovery of costs.” On rates, Inteliquent says NTPs would volunteer for caps, set the way the Commission set 8YY tandem rates, and that it is willing to work on the proposal “including by revisiting the proposal to tariff NTP transit rates.”

The Competitive Carriers Association, with ATNI, Nsight/Cellcom and Viaero, met fifteen WCB staff, including Deputy Chief Jodie Griffin and the heads of the Competition Policy and Pricing Policy divisions. CCA said its members cannot get IP interconnection from major carriers while paying “anticompetitive TDM expenses,” and backed Bandwidth’s request for a freeze of TDM interconnection prices or an investigation. It also raised the number and location of points of interconnection and continued USF support for rural areas.

Discontinuance rules take effect October 15

The Wireline Bureau’s DA 26-1061, released October 1, announces that OMB approved the information collections in FCC 26-19 on September 21 and 25, and that the amended sections 51.329, 51.333, 63.60, 63.62, 63.63, 63.71 and 63.602 take effect October 15. Every discontinuance application and network-change notice from that date must follow the new rules. The notice opens WC Docket 26-214 as the master docket where customers can comment on or object to a technology-transitions discontinuance without tracking the individual public notice. Carrier notices to customers must name that docket and link the FCC’s “Tech Transition” and “When Your Telephone Company Discontinues Service” guides; the Bureau did not prescribe wording. It encourages carriers to ask objecting customers to include the notice itself or the carrier name, location, notice date and planned discontinuance date.

Seven individuals filed express comments in WC 25-209 between September 26 and October 2, one of them also in 25-208.

The revocation order: “one” is in, the 12-month delay is out

FCC 26-67, adopted September 30 and released October 1, lets callers treat a revocation as covering only the category of informational robocall it answered, and lets them designate one or more of three methods as the exclusive way to revoke: an automated voice or key-press mechanism, a reply text using a standardized word, or a website or phone number. The designated method has to be disclosed on the call or in the message. On the keyword question the banks and Vibes raised, the Commission sided with them: “we clarify that text senders can satisfy the disclosure requirement by disclosing even just one of the standardized words in each text message.” The adopted rule reads “any one of the following standardized words,” and senders still have to honor all seven.

The rules take effect 30 days after Federal Register publication and replace the January 31, 2027 waiver date for the revoke-all provision. The Commission declined, citing Vibes, “the request of one party to extend the effective date up to 12 months after Federal Register publication.” The order does not take up Vibes’s code-level opt-out. The five-minute presumption for confirmation texts stays in the rule. The fraud-alert exemption now reaches numbers from a spouse or authorized family member on the account, numbers captured when the customer calls in, and numbers in records from another financial institution, and the Commission grants ABA’s 2015 reconsideration petition to that extent. The order adds: “we encourage financial institutions to make use of resources such as the Reassigned Numbers Database (RND).”

The FNPRM takes up the June 30 joint letter from ABA, NCLC and ACA International: cutting the ten-business-day window to honor revocations (the letter suggests seven), eliminating the provision that lets senders use one-way texting protocols, requiring a revoke-all method, and how revocation applies across affiliates and lines of business. It also asks about confirmation calls or texts and about Vibes’s request that a confirmation text be allowed to ask which category the consumer meant. Comments are due 30 days after Federal Register publication, replies 60. Carr and Trusty issued statements.

AI-voice political calls: comments due Monday

Comments on the Club for Growth petition close October 5 under DA 26-940, with replies October 19. The petition asks for a waiver and exemption so callers can make noncommercial political calls to wireless numbers using an artificial or prerecorded voice, “including an AI-generated voice,” without prior express consent. The same notice covers Joe Shields’s petition asking the Commission to declare that a P2P texting system using “a perfunctory human being” to click send is an autodialer. NCLC posted an action page on September 24 asking people to file in CG 02-278; five express comments were filed there between September 28 and 30. Sue Present of Silver Spring, Maryland filed a two-page comment on October 2 citing the January 2024 New Hampshire primary calls and arguing that “the petition’s proposed 10-day opt-out grace period is entirely ineffective in an election cycle.”

911: the NOI is out, and the PS/ALI problem is every wireline OSP’s

FCC 26-63, the Modernizing the 911 Framework NOI in PS 26-197, sets comments for November 16 and replies for December 15. It asks about the core objectives of the 911 framework, the four-factor scope test, harmonizing obligations across services, and legal authority. On the PSTN-interconnection factor it questions “whether ‘PSTN interconnection’ continues to make sense.” On competition with traditional telephone service it asks: “Should AI affect how we determine what services and devices fall within the scope of 911 requirements, and what benefits or risks should we consider?” As one harmonization option it floats a baseline set of functional capabilities for all providers, naming “location, callback number, and routing to the appropriate 911 Authority.”

PSHSB released an order on September 28 conditionally granting Verizon a limited waiver of the NG911 Phase 1 deadline for wireline service, through June 30, 2026 in Massachusetts and other listed jurisdictions that filed Phase 1 requests before November 1, 2025, and through July 31, 2026 for those that filed between November 1, 2025 and January 31, 2026. During Massachusetts connectivity testing, 911 calls from TDM multi-line telephone system customers using third-party PS/ALI service were going to a national call center because Verizon did not have their location data. The order quotes Intrado: “No other carriers, 9-1-1 vendors, or industry experts identified this architectural interaction between legacy PS/ALI products and Phase 1 SIP connectivity until Verizon’s January 2026 [FOA] testing revealed it.” A companion public notice puts the rest of the industry on notice: “we consider all wireline OSPs to be on notice of the need to assess whether they will face similar issues,” and advises them to check for MLTS customers on third-party PS/ALI service even before a Phase 1 or Phase 2 request arrives.

FailSafe Communications filed supplemental comments on September 28 responding to last week’s outage-notification notice. It cites an outage the day before the notice that disrupted 73 of Oklahoma’s 122 call centers, attributed by the state 911 coordinator to an AT&T switch failure, and argues that “A provider cannot provide actionable information about a 911 failure it has not discovered.” FailSafe proposes using originating-network signaling to detect failed 911 attempts, and describes its patented T911 product as one way to do that.

Authentication: extensions kept, labels contested, and a counting proposal

The Wireline Bureau’s DA 26-1050, released September 29, is the annual TRACED Act reevaluation of STIR/SHAKEN undue-hardship extensions. Both remaining extensions stay: providers that cannot get an SPC token because of the Governance Authority’s policy, and small providers originating calls via satellite with NANP numbers. The Bureau says keeping them “will ensure continued stability across the voice ecosystem” while the Commission decides whether to repeal them in the KYUP FNPRM, and it did not seek separate comment this year because the FNPRM already asked.

Unified Office CEO Ray Pasquale, five colleagues, customer Ronny Hakim of Honda of Hackettstown, and Glenn Richards of Dickinson Wright met nine WCB and CGB staff on October 1 and filed the next day. UO signs all its calls with A attestation and still sees them labeled spam. It asks that originating providers be notified when a call is labeled, with a reason code naming who made the classification, that the originating carrier’s caller name be preserved on A-attested calls, and that STIR/SHAKEN be extended to authenticate caller name end to end with CNAM and Rich Call Data. The attached log covers 36 support tickets from December 2021 to September 2026, 13 naming Verizon, and quotes Verizon’s reply on flagged numbers: “We believe this categorization to be accurate.” One case was confirmed fixed, through Hiya, AT&T’s analytics vendor, in two days. UO also raised analytics firms that mislabel calls and then offer to remove the label for a fee; its deck calls the paid fix “Branded Calling.”

Nathan Nelson of Number Sentry and Ronald Grob of APELA filed an open letter in WC 25-304, WC 17-97 and CG 17-59 asking the Commission to seek comment on a “VoIP interconnection accountability standard.” Their point is that the STIR/SHAKEN, RMD and SIP 603+ rules each define an obligation, but “None of them produces a recurring, count-based record of what crosses a given interconnection.” They propose that carriers count SIP attempts at each interconnection and report, against those totals, Identity header presence, attestation level and verification result, analytics-based 603+ blocks, policy-check rejections, and rerouted traffic, starting with direct interconnections to AT&T, T-Mobile and Verizon.

Honorable mentions

M3 USA, through Paul Werner of Sheppard Mullin, objected on September 28 to dismissal under DA 26-867 of its 2017 petition on whether research-survey faxes are advertisements; its Southern District of Florida case has been stayed for nine years waiting on the answer. Jennifer Richter of Akin Gump met CGB’s Mark Stone and staff on September 23 to oppose the reinstated Cin-Q application for review of the Bureau’s 2020 fax-broadcaster sender-liability ruling (cross-listed in CG 05-338 and CG 25-307).

The FTC’s impersonation-platforms ANPRM was published at 91 FR 62347 on October 1; comments are due November 30 in docket FTC-2026-1552.

Six carriers filed rip-and-replace status updates or extension requests in WC 18-89.

Looking ahead

Club for Growth comments close Monday, October 5, with replies October 19. RMD FNPRM comments are due October 9. The FCC 26-19 discontinuance rules and the WC 26-214 master docket go live October 15. Federal Register publication of FCC 26-67 will start the 30-day effective-date clock and set the FNPRM comment dates. ATIS letter ballots on the first two ALIII documents are scheduled for November.