In case you weren’t aware Washington Broadband has a sister company called Washington Telco LLC. It is a Competitive Local Exchange Carrier (CLEC), with our own phone switch, it’s a phone company on equal footing with Lumen, Ziply, Consolidated, and the like. We offer phone service over Internet (VoIP/SIP) to our customers, and in some cases to off network people as well. We offer residential service at costs less than the major carriers (not cell phones), and commercial PBX service that operates in the cloud, so buying a business PBX is unnecessary, for far less monthly cost with phone line included.

While we do maintain the washingtontelco.com domain we just forward it to our parent company Washington Broadband website. There are many more laws written for phone companies, one of those is to post our anti-spamming policy on the website. This is why I am posting our Acceptable Use Policy (AUP), as required by law. Here it is:

Robocall Mitigation Plan

Business Information

Washington Telco, LLC

3201 W. Nob Hill Blvd.

Yakima, WA 98902

Contact Information

Forbes H. Mercy

President

509.853.0858

forbes.mercy@washingtontelco.com

Overview

The FCC requires that all small voice service providers (“VSPs”) certify in the Robocall Mitigation Database that they have implemented a Robocall Mitigation Plan (“RMP”) to ensure that they are not originating illegal robocalls.

The FCC requires that VSPs develop a RMP that:

• details the reasonable steps taken to avoid originating illegal robocalls;
• demonstrates a commitment to respond to traceback requests to cooperate with investigators and stopping illegal robocalls; and
• is filed in the Robocall Mitigation Database.

The FCC states that a RMP is sufficient if the detailed practices in the plan can reasonably be expected to significantly reduce the origination of illegal robocalls and the VSP complies with the practices it describes in its filing.

Purpose

Washington Telco, LLC (“WTL”) is dedicated to stopping illegal calls from originating in our system and monitoring the calls coming into our system. This document delineates WTL’s RMP.

Know Your Customer (“KYC”)

The accurate identification of a subscriber in the STIR/SHAKEN ecosystem is tied to a telephone number-based caller identity associated that subscriber. A subscriber is an entity that has a business relationship with WTL in which we transmit, originate, and/or terminate calls based on behalf of the subscriber.

WTL’s KYC program involves obtaining specific information from its subscribers. This process includes collecting such information such as:

• physical business location;
• contact person(s); and
• nature of customer’s business.

Acceptable Use Policy (“AUP”)

WTL maintains an AUP that subscribers must agree to before being permitted to use WTL’s system. Among other things, the AUP prohibits:

• providing altered, deceptive, or false information about the identity of the sender or the origin of a message or phone call;
• violating any applicable local, state, or federal law; and
• using WTL’s service to engage in or in connection with fraudulent activities.

WTL’s terms of service with subscribers specify that WTL may take action up to suspension or termination of service for violation of the AUP.

Monitoring  

WTL works with its upstream carrier to analyze high-volume voice traffic in order to identify and monitor patterns consistent with robocalls. If WTL detects a calling pattern consistent with illegal robocalls, we will identify the party and will appropriate action. Taking appropriate action may include, but is not limited to, initiating a traceback investigation, verifying that the originating subscriber owns or is authorized to use the Caller ID number, and suspending or terminating the party’s ability to originate calls on our system.

Investigate Suspicious Activity

When traffic analysis indicates the presence of likely illegal robocalling, WTL follows the defined procedures on investigating such subscribers.

The procedures established include but are not limited to:                

• checking recent and past call detail records and benchmark against expected trends;
• checking recent and past account activity and purchases;
• investigating if any system issue generates the strange behavior;
• verifying that the call originating path is valid; and
• contacting the subscriber to understand his or her particular use case and validate that the activity belongs to that subscriber.

WTL is familiar with and uses best efforts to follow the Industry Traceback Group (“ITG”)-recommended best industry practices and cooperates in traceback and trace forward investigations. To allow for timely and comprehensive responses, WTL will devote sufficient resources to provide prompt and complete resources to traceback requests.

Blocking

WTL will implement Do Not Originate requests it receives from the ITG. WTL has procedures to block suspicious calls. If WTL identifies suspected robocalling patterns that are confirmed with further investigation, WTL will take appropriate action which may include suspending or terminating the subscriber’s use of WTL’s system. WTL will cooperate with Investigative Bodies (provide a single point of contact to address traceback requests from law enforcement (including the state attorney general’s office), to the FCC, and/or the ITG; as well as documenting requests & actions taken in response thereto.

Plan Updates

This plan and industry best practices must evolve to response to the dynamic nature of mitigating illegal robocalling. WTL will monitor industry best practices and continuously improve our internal processes to ensure this plan and our system adapt to this ever-changing issue.

In the event of any material change to this plan, WTL will republish it to employees, consultants and contractors and file such an update to the FCC Robocall Mitigation Database within ten (10) days of such update.