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Reply To Comments by ACA International in 24-213

The Federal Communications Commission proposed expanding the definition of Voice Service Providers to include entities such as call centers and PBXs within the Robocall Mitigation Database framework. Industry stakeholders argue this expansion contradicts the TRACED Act's statutory definition, which limits the term to services interconnected with the Public Switched Telephone Network. Critics contend that including non-interconnected entities would flood the database with filings, reduce transparency, and impose significant compliance costs on small businesses without a regulatory flexibility analysis. Consequently, these entities maintain that call centers function as end users rather than providers and lack the technical ability to monitor network traffic or facilitate call tracebacks.

Submission type
REPLY TO COMMENTS
Filers
ACA International
Authors
Michael H. Pryor
Law firms
Brownstein Hyatt Farber Schreck, LLP
Proceedings
24-213 Improving the Effectiveness of the Robocall Mitigation Database
17-97 Call Authentication Trust Anchor
17-59 In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls
Submitted
Nov 9, 2026, 4:19 PM ET
Disseminated
Nov 10, 2026, 11:00 AM ET