On May 3, 2024, the Voice on the Net Coalition (VON), met via video conference with the FCC. This document summarizes what VON proposed at that meeting. The companies behind VON are much more than those listed on their website. It includes the likes of Microsoft (hence the focus on UCaaS, Microsoft Teams), Google, Amazon, Cisco, Vonage, and the carriers. Given that group, this proposal ticks all the politically correct boxes and treads a fine line in asking for action by the FCC by asserting jurisdiction over telephone numbers, not SMS itself.

The purpose of the meeting was to discuss VON’s core proposal that the FCC require and oversee a process whereby a neutral, third-party entity is selected to vet application-to-person (“A2P”) traffic on a technology-neutral basis, with policies applied equally to all traffic regardless of whether the traffic in question is initiated via a Unified Communications as a Service (“UCaaS”) platform or directly on a mobile network operator (“MNO”) network.

This is because TCR is owned by Tata Communications, a UCaaS provider and SMS aggregator that is not neutral. Global Telco Consult’s TCR (The Campaign Registry) report includes this quote from T-Mobile on their ownership concern:

“Regardless of data protection, there was a commitment to get out of the messaging space to keep TCR proposition ‘clean’.

A relationship meant to be based on trust but ‘built on a lie’.”

GTC Report Slide 23

In the VON document they also state:

“Unfortunately, VON members and the organizations they serve have experienced substantial difficulty in helping these organizations communicate via texting due to inefficiencies and imbalances in the current system for vetting text messages.”

We covered this last year in the Messaging Monopolies and Telecom Triopolies posts.

The VON representatives are suggesting that the Industry Traceback Group (“ITG”) could serve as a model for a neutral registration entity, not because VON is proposing traceback of text messages, but because the FCC played a similar role in selecting and ensuring the accountability of the industry-led ITG. See diagram below.

Context

The complaints about the TCR have accelerated this year, see this video from Eric Troutman, 

There’s a very delicate line being walked here, they are asking for FCC oversight, not regulation of SMS. 

Normally, Glenn Richards does these FCC filings for the VON Coalition, but as he’s worked for TCR, he likely could not be involved. The legal firm Covington, I believe, does work for Microsoft and Google; likely Microsoft is driving this because of the focus on UCaaS.

As covered in the Messaging Monopolies and Telecom Triopolies posts, it’s not just UCaaS providers, CSPs (Campaign Service Providers), brands, CCaaS (Contact Center as a Service), enterprises are all impacted across many workflows.