The Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act) requires voice service providers to implement STIR/SHAKEN authentication on Session Initiation Protocol (“SIP”) traffic on carrier networks as well as to implement a Robocall Mitigation Plan (“RMP”) covering non-SIP Time Division Multiplexing (“TDM”) traffic.

Team IHA, Inc. (“The Telephony Co IHA”) serves as a provider of “voice service” as set forth in §64.6300(l) of the Federal Communications Commission’s (“Commission”) rules, 47 C.F.R. §64.6300(l). The Telephony Co IHA’s offerings include a range of voice services, including Cloud Telephony, SIP Trunking, Hosted PBX, and VoIP services. The Telephony Co IHA services cater to businesses of all sizes, providing solutions for both inbound and outbound communications. The Telephony Co IHA lacks control of network infrastructure necessary to fully implement the STIR/SHAKEN framework on the network supporting The Telephony Co IHA’s customer base

The Commission grants The Telephony Co IHA a continuing extension for implementing STIR/SHAKEN authentication for TDM traffic provided The Telephony Co IHA comply with Commission rules applicable to such portions of the The Telephony Co IHA network subject to extension. To this end, The Telephony Co IHA hereby submits this RMP to the Robocall Mitigation Database describing and confirming practices, policies, and procedures to mitigate unlawful robocalling, which include the following:

(1) The Telephony Co IHA’s specific reasonable steps to avoid originating illegal robocall traffic as part of this RMP;

(2) The Telephony Co IHA’s commitment to respond fully and timely to all traceback requests from the Commission, law enforcement, and the industry traceback consortium, and to cooperate with such entities in investigating and stopping any illegal robocallers using TIHA’s service to originate calls; and,

(3) The Telephony Co IHA’s intent to participate in industry tradeshows, groups, or consortiums, working to strengthen efforts to combat unlawful robocalling, and additional call verification and authentication solutions.

As part of TIHA’s RMP, The Telephony Co IHA provides the following affirmative, effective measures to help minimize the impact of illegal or unwanted robocalls, and prevent new and renewing customers from using The Telephony Co IHA to originate illegal calls:

• Automatic Number Identification Management: The Telephony Co IHA shall block originating telephone numbers if identified based upon patterns of activity.
• Proactive Blocking. The Telephony Co IHA requests underlying carriers to block calls from phone numbers on Do-Not-Originate lists published by US Telecom and Neustar.
• General Terms and Conditions. The Telephony Co IHA prohibits customers from originating fraudulent calling using any fraudulent means, devices, or technologies. In fact, The Telephony Co IHA’s end user Terms and Conditions permit The Telephony Co IHA, without notice, to discontinue, block or suspend Services if necessary to prevent fraud, scams, tampering, schemes, false or invalid numbers. In short, The Telephony Co IHA shall block or suspend the service of any customers originating unlawful robocalls through The Telephony Co IHA. The Telephony Co IHA’s RMP includes an increasing investment in resources over time to further strengthen adherence to compliance requirements by customers.
• Acceptable Use Policy. The Telephony Co IHA’s Acceptable Use Policy (“AUP”) also prohibits customers from utilizing the Service for any illegal, fraudulent, objectionable and/or unauthorized manner, reserving the sole and absolute right to deny, restrict or immediately suspend or terminate service if the use of the service by the customer, or anyone having access to or using the service, either violates the The Telephony Co IHA AUP or includes unlawful conduct.
• Underlying Network Provider. The Telephony Co IHA works with underlying providers and supports the benefit of deploying systems to detect potential robocall activity relying upon statistics such as average call duration, ASR, and call count carrier/consumer reports. The Telephony Co IHA’s regulatory compliance counsel confirms that The Telephony Co IHA’s underlying carriers maintain compliance with fully implemented STIR/SHAKEN protocols through the date of this RMP.
• Traffic Reports and Industry Information. Reports generated by Call Detail Record and pattern trends, fraud information sharing through industry organizations, and third-party notifications and complaints, may identify potential unlawful robocalling. Although no evidence exists suggesting The Telephony Co IHA in any way originates illegal robocall campaigns, in any instance where unlawful calling is identified, The Telephony Co IHA maintains contractual ability to take any action it deems necessary to eliminate the fraudulent activity.

The Telephony Co IHA maintains a comprehensive customer vetting process to meet “Know Your Customer” (“KYC”) obligations. This KYC vetting process provides an understanding of the nature of activities for any new and existing customers. Identifying and understanding customers through this KYC vetting process diminishes the opportunity to use The Telephony Co IHA’s network for spoofed or illegal traffic.

The Telephony Co IHA offers voice Services using over physical lines or connections sold by The Telephony Co IHA to Customers relying upon the physical networks of underlying providers for call termination, call origination, 911 and assigning working telephone numbers. The Telephony Co IHA lacks control of network infrastructure necessary to fully implement the STIR/SHAKEN framework on the network supporting The Telephony Co IHA’s customer base, relying in most instances upon underlying providers in obtaining the highest attestation levels possible with all voice calls. The Telephony Co IHA and underlying network providers affirmatively commit to fully implementing STIR/SHAKEN. In addition to contractual mechanisms, The Telephony Co IHA interfaces with underlying providers with regard to a number of important service and network issues, including measures combatting unlawful robocalling along with authentication solutions.

At no time since inception has The Telephony Co IHA been suspected or investigated for carrying illegal robocalls originating on The Telephony Co IHA’s network. Further, no Commission, law enforcement, or other regulatory action or investigation exists involving The Telephony Co IHA due to unlawful robocalling or spoofing. Finally, no law enforcement or Commission action bars The Telephony Co IHA from the RMD. The Telephony Co IHA remains committed to maintaining this level of compliance and will respond fully and timely to all traceback requests from the Commission, law enforcement, and the industry traceback consortium, and to cooperating with such entities in investigating and stopping illegal robocallers using The Telephony Co IHA service to originate calls. The Telephony Co IHA commits to working with the FTC and state attorney general counsels participating in traceback, further demonstrating commitment to such important efforts.

• The Telephony Co IHA operates under the business name Team IHA, Inc. and The Telephony Co.
• The Telephony Co IHA’s primary address is 919 North Market Street, Suite 950, Wilmington, Delaware 19801.
• The Telephony Co IHA is not a foreign provider.
• The name, title, department, business address, telephone number, and email address of one person within the company responsible for addressing robocall mitigation related issues follows:

NOC The Telephony Co
noc@thetelephony.co
+3322200228

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