appliedbits
DISPATCH  ·  Regulatory Watch PUBLISHED
PUBLISHED 2026-11-07

Week ending November 6, 2026

FracTEL told the Commission on November 2 that it has logged about 3.3 million suspected illegal calls since June that presented its own unassigned or disconnected numbers and carried A-level attestation. ZipDX, Sirveil and AB Handshake filed on the robocall dockets the same week, ahead of the November 9 reply date in the RMD FNPRM. On November 5 the Commission released the text of its international §214 order (FCC 26-74), and Lumen asked to grandfather four of its VoIP and SIP voice products in all 50 states.

Robocall record before the November 9 reply date

FracTEL’s supplemental ex parte (Michael Crown; WC 26-49, 20-67, 13-97, 07-243) is about numbers it holds but did not assign. It says it correlates caller ID on monitored traffic with its own assignment records and finds calls using numbers that “were disconnected, unassigned, or undergoing aging procedures before reassignment,” signed at A. From that it concludes “the presence of A-level attestation does not establish that the caller was authorized to use the number and there is currently no reliable method to enforce authority, nor is there a reliable way for downstream carriers to check or challenge attestation.” Its argument against the numbering proposals is that they address “who may obtain telephone numbers” but not “who may lawfully use those numbers as caller identification.” FracTEL says the spoofing has damaged the reputation of its numbers, that it has had “substantial difficulties” getting reputation labels corrected, and that it has been sued over calls it did not originate. It asks the Commission to tighten accountability for providers that sign at A without checking authorization, and to recommend that Congress add a private right of action to §227(e). The filing lands in the same dockets as the numbering-access order on the November 19 agenda.

David Frankel of ZipDX met WCB, CGB and OEA staff on November 2 and filed the deck (WC 17-97, 24-213; CG 17-59, 02-278). Its premise: “The universe of SHAKEN signers is tractable.” The proposals:

  1. Per-call liability for illegal calls, attaching to “the signer shown at the terminating end, and everybody upstream,” which a provider limits by taking indemnity from its source and only accepting signed calls.
  2. Single-line customers without verified government ID get signed calls with RCD showing “Anonymous.” High-volume, short-duration callers must use and pay for branded calling with full vetting.
  3. Terminating providers with more than 10 million subscribers must offer signer-reputation protection, opt-in or opt-out, with no liability.
  4. The RMD becomes a gatekeeper with FCC-set vetting and provider tiers split at 1 million calls a month.
  5. TDM capacity capped at historical levels, non-STIR/SHAKEN traffic reported in the RMD, and “Deprecate B-level attestation.”

Two RMD FNPRM (FCC 26-49) replies arrived early. Sirveil (Ben Tobin), which discloses a commercial interest in how compliance claims are checked, picks up USTelecom’s request that providers be allowed to rely on the Database. Its point: “A certification under penalty of perjury raises the cost of a false statement once it is caught. It does not record whether anyone has looked.” It asks that each RMD entry show, for elements that can be checked from outside, whether anyone other than the filer has confirmed them and when, and that a missing confirmation not be grounds for removal. AB Handshake (Nadejda Papernaia) makes a similar distinction, “A provider can be properly registered, and its calls can pass STIR/SHAKEN authentication, yet fraudulent activity may still occur,” and backs an effective-measures standard judged on operational evidence. Its two citations to the INCOMPAS/Cloud Communications Alliance comments carry the note “pinpoint verification required.”

IPtelX and DICE returned with data after a November 4 meeting with 15 staff from WCB, CGB and PSHSB on alarm-monitoring calls. In the meeting Clifford Dice estimated that about 25 percent of calls into 911 centers come from monitoring centers. David Furth of PSHSB said he did not know the figure, and the letter replaces it with a 2011 DOJ estimate that false alarms make up 10 to 25 percent of calls to police. Monitoring Center A logged 2,032 dispatches from October 6 to November 4. In 868 of them the center called a contact first, and nobody was reached in 539 (62.1 percent). The filing says it “does not determine why contacts were not reached.” It asks for a vetted alarm-monitoring category under FCC 26-32 paragraph 130.

FCC 26-74: the international §214 order text

The Report and Order and FNPRM (IB 23-119), adopted October 29, was released November 5. The Commission declined the 10-year renewal requirement and the three-year periodic review it proposed in 2023. It relies instead on application certifications, routine conditions, a second one-time collection, and a 30-day obligation to report material changes.

Only about 1,235 of roughly 7,000 holders answered the 2023 collection. For the rest: “We deem the failure of an authorization holder to respond to the Evolving Risks Order as presumptive evidence that the authorization holder is no longer in operation.” OIA will publish the non-responders in the Federal Register with 30 days to respond or surrender. A second notice gives 15 more days, then OIA revokes.

The Covered List condition reaches only covered equipment or services “that are based on producer/provider-based determinations,” not the production-location entries PSHSB has added since December 2025. The draft VoIP numbering order uses the same limit. Holders granted after the rules take effect may not use or add such equipment; existing holders may not add it. Applicants must also say whether they use third-party providers that are foreign adversary-controlled, on the Covered List, or able to reach the network “from a foreign adversary country.”

Applicants assigning or transferring an international §214 authorization must now list any SS7 International Signaling Point Codes they hold and say whether the codes go with the deal. CTIA called the rule “redundant.” The Commission cites China Unicom (Americas), which “admitted that it had failed to notify the Commission of the transfer of ISPC 3-194-2 from China Netcom (USA) Operations Limited to China Unicom USA Corporation in August 2009,” an admission made in June 2020. The FNPRM proposes a presumption against grants to foreign adversary-controlled applicants and Covered List entities. Comments are due 30 days after Federal Register publication, replies 60.

All-IP: Lumen’s VoIP lines, Georgetown’s copper, a protective order

WCB accepted for filing (DA 26-1189, WC 26-292) Lumen’s application to grandfather VoIP Enhanced Local Service, Local Inbound, Lumen Hosted VoIP and Lumen IQ SIP Voice in all 50 states, D.C. and Puerto Rico. On or after December 4 the services “will no longer be available for new orders for new or existing customers.” ELS and Local Inbound contracts go month-to-month at term, and Hosted VoIP and IQ SIP Voice contracts end at term. Comments are due November 18. A day earlier the Bureau opened comment (DA 26-1185, WC 26-291) on Georgetown Telephone’s technology-transition discontinuance of copper/TDM voice, E911, PRI and exchange access in parts of Copiah and Simpson counties, Mississippi. Comments are due November 17, and the authorized date is December 5.

On November 4 the Bureau adopted a Protective Order (DA 26-1191) covering the IP interconnection, network modernization, call authentication, all-IP reform and high-cost dockets (WC 25-304, 25-208, 17-97, 25-311, 26-96, 10-90). Highly confidential treatment is limited to categories in its Appendix A, including “[d]etailed or granular information about specific equipment or network facilities and operations.” Vantage Point Solutions told staff (Jeffry Smith; WC 25-311, 25-208) it supports starting the five-year CAF-ICC freeze on January 1, 2027, followed by a four-year phase-out if the freeze meets its objectives. It wants waiver criteria for states where PSAP or anchor-institution IP transitions lag.

OEA’s Voice Telephone Services report for December 2025 counts 13.5 million retail switched access lines, down from 24.4 million in December 2022, a 17.9 percent annual decline. Interconnected VoIP fell to 61.8 million. Mona DeKock and Mike Huff objected in WC 26-214 to losing Frontier copper that their fire alarm depends on. WC 26-214 also took three express comments without attachments. In WC 25-208/25-209, Matthew Looney asked that copper be preserved in place where it is sound, while Lee Widman asked that carriers be required to remove all of it.

CGB announced (DA 26-1200) that TRS rules from the 2023 VRS Improvements, 2024 IPCS and 2024 IVCS orders took effect November 5 after OMB approval, including VRS contractor reporting and enterprise TRS registration in carceral facilities. In the 911 NOI (PS 26-197), the Washington State 911 Coordination Office says the voice-and-PSTN scope test “is no longer accurate, or effective, as a regulatory base.” It wants broadband transport brought into 911 rules, satellite direct-to-device providers barred from using relay centers as their default path to the PSAP, and STIR/SHAKEN “adapted for emergency paths” on international roaming interfaces.

Honorable mentions

The D.C. PSC, Arizona Corporation Commission and Maine PUC staff petitioned (CC 99-200, 96-98, 95-116; WC 13-97) to end the 2002 exemption that lets paging companies take full CO codes instead of thousands-blocks. They cite a 5.3 percent national paging utilization rate in 2022, and state findings that “the numbers are instead being used for unrelated voice services via Voice over Internet Protocol (VoIP)” by paging affiliates. ConnectTo Communications filed a VoIP direct-access application dated April 2025 in WC 13-97, ahead of the vote on new certification rules for those applications. Neil Goldstein, commenting on the FCC 26-67 FNPRM (CG 02-278), describes a call from his own Part D plan whose AI agent, “Kathy,” asked for his date of birth before saying who it was: “In those first thirty seconds I had no way to verify the caller before the caller verified me.” He asks that automated callers disclose that they are machines and state who is calling before requesting personal information. Election Day passed with no Bureau action in CG 02-278 on Club for Growth’s AI-voice political-call petition. The FTC’s Impersonation Rule docket (FTC-2026-1552) has taken 103 comments since October 30, nearly all from individuals. Two small carriers filed rip-and-replace extension requests in WC 18-89.

Looking ahead

RMD FNPRM replies are due Monday, November 9. The Sunshine notice for the November 19 meeting, which carries the VoIP numbering-access order and the TRS compensation NPRM, should post around November 12 and close the ex parte window. Comments on the 911 NOI are due November 16, on Georgetown’s discontinuance November 17, and on Lumen’s grandfathering November 18. Federal Register publication of FCC 26-74 will set its FNPRM dates and start the 30-day clock for the 2023 non-responders.