This Robocall Mitigation Plan is being submitted by Clear Voice Networks, LLC, in accordance with the requirements of 47 C.F.R. § 64.6305. As a voice service provider, we are committed to establishing and implementing effective measures to reduce the occurrence of illegal robocalls originating on our network.
Policies and Procedures for Robocall Mitigation
Outlined below are the policies and procedures that Clear Voice Networks, LLC currently has in place to mitigate the impact of outbound illegal robocalls:
1. Call Authentication
We have implemented call authentication technologies, such as the SHAKEN/STIR framework, to verify the legitimacy of calls originating on our network. This helps prevent the spoofing of Caller ID information, a common tactic used by illegal robocallers.
2. Call Monitoring and Analysis
We actively monitor and analyze call traffic on our network using advanced analytics tools and algorithms. This enables us to identify patterns and anomalies associated with robocalls, allowing us to take prompt and appropriate actions.
3. Traffic Filtering and Blocking
To proactively prevent the origination of illegal robocalls, we employ traffic filtering and blocking mechanisms. These mechanisms are continuously updated based on industry best practices and intelligence gathered from our network monitoring activities.
4. Customer Education and Awareness
We are committed to educating our customers about the dangers and impact of robocalls. Through various communication channels, we provide information and resources to help our customers understand how to protect themselves from illegal robocalls and how to report any suspicious activity.
5. Cooperation and Collaboration
Clear Voice Networks, LLC is dedicated to collaborating with industry stakeholders, including the FCC, law enforcement agencies, and industry groups like the ITG. We commit to promptly responding to traceback requests within 24 hours and actively cooperating in any investigations aimed at identifying and stopping illegal robocallers using our services.
By implementing these policies and procedures, we demonstrate our commitment to combatting the issue of illegal robocalls and protecting against unwanted and fraudulent calls. We continuously assess and update our strategies to stay ahead of evolving robocall techniques and ensure the effectiveness of our mitigation efforts.
I. STIR-SHAKEN Implementation Status
The Provider’s status regarding the implementation of STIR-SHAKEN is as follows, according to the FCC’s Robocall Mitigation Database:
Clear Voice Networks, LLC has successfully implemented the STIR-SHAKEN authentication framework on its network. Calls originating from our network are compliant with the regulations stated in 47 CFR § 64.6301(a)(1) and (2). The Provider has also established policies and procedures outlined in its Robocall Mitigation Plan to prevent the use of its service for illegal robocalls.
II. Traceback Requests
Clear Voice Networks, LLC acknowledges its commitment to support and collaborate with the FCC, law enforcement agencies, and the ITG in tackling illegal robocall activities. This includes promptly responding to and complying with all traceback requests and investigations. The Provider will allocate adequate resources to ensure the completion and provision of responses to traceback requests within a reasonable time frame. It commits to responding fully to any traceback request received within 24 hours of receiving the request.
III. Additional Measures
To facilitate the effective traceback of illegal robocalls, Clear Voice Networks, LLC will incorporate specific provisions in its carrier interconnection and/or service agreements. These contractual clauses will require all parties involved to cooperate in the traceback process of voice service calls. The provisions will outline the importance of promptly identifying the upstream provider responsible for introducing a suspected illegal robocall into their network or the customer from whom the call originated. This step will enhance collaboration and accountability among parties in combating illegal robocalling activities.
IV. Customer Vetting Practices
Clear Voice Networks, LLC implements industry best practices to verify the identity of all its voice service subscribers. The subscriber vetting process aims to ascertain the authenticity and legitimacy of customers, forming the basis for establishing a business relationship.
To ensure compliance with legal requirements and promote ethical conduct, the Provider collects essential information from customers, such as their physical location, contact person(s), state or country of incorporation, federal tax ID, and details regarding the nature of their business. Gathering this information helps confirm the identity of customers and assess their suitability for the services they seek.
V. Telephone Number Validation
Clear Voice Networks, LLC has procedures in place to confirm the calling customer’s right to use a telephone number. The Provider screens all originating calls and only allows calls to be connected if the originating number matches one of the numbers assigned to the subscriber. These screening capabilities enable an automated and secure method of validating originating telephone numbers.
VI. International Call Originators
Clear Voice Networks, LLC is not currently an international voice services provider and has no plans to offer such services.
VII. Know Your Customer (KYC)
Sales, Product Management, and Business Operations teams conduct risk assessments.
Customers are required to provide legal business information, which is reviewed by the Finance team.
Contract language mandates customer cooperation in eliminating fraud and misuse.
A combination of automatic systems and manual reviews evaluates the legitimacy of incoming voice communications.
VIII. Ongoing Robocall Mitigation Practices
Clear Voice Networks, LLC monitors network usage and examines call detail records (CDRs) on a recurring basis to detect suspicious call activity and/or calling patterns. When network usage patterns consistent with illegal robocalls are detected, we take immediate action, including initiating a traceback investigation and verifying the legitimacy of the originating customer.
IX. Third-Party Call Analytics
Clear Voice Networks, LLC also uses third-party call analytics to prevent the origination of illegal robocalls on its network.
Call Analytics Vendor Name and Description of System
Name of Vendor: TransNexus
Description: Call analytics purchased from the vendor determine if originating calls should be blocked. If the telephone number appears on a Do-not-call list or is an unallocated, unused, or invalid number, the call is flagged as fraudulent and blocked. Advanced fraud detection enables behavior analysis and tracking of abnormal and unexpected calling patterns to detect high-volume robocalling, spoofing, and suspicious call activity.
Clear Voice Networks, LLC remains dedicated to providing a safe and secure voice service environment and is committed to taking all reasonable steps to prevent the origination of illegal robocalls on our network.