FCC Seeks Comment on Autodialed Calls to Reassigned Numbers

On March 23, 2018, shortly after the court set aside the FCC’s rule establishing a one-call safe harbor for reassigned numbers, the FCC released a Second Further Notice of Proposed Rulemaking seeking comments on establishing databases to prevent unwanted calls to numbers that have been reassigned. Under this proposal, one or more databases would be developed to provide callers with the comprehensive and timely information they need to discover that a number has been reassigned before making a call to that number. The Commission proposes that the database would provide callers with information about when numbers are disconnected. The FCC reasons that this will best allow callers to identify, at the earliest possible point, when a subscriber can no longer be reached at that number. According to the FCC, “with timely access to such data, callers will be best positioned to rid their calling lists of reassigned numbers before calling them.” The FCC seeks comment on whether callers who choose to use the reassigned numbers database should be afforded a “safe harbor” from TCPA liability for all calls to reassigned numbers in the database, or some subset of such numbers.

In connection with this proposal, the FCC seeks comment on 1) the specific information that callers who choose to use a reassigned numbers database need from such a database; 2) how to ensure that the information is reported to a database; and 3) the best way to make that information available to callers who want it.  The FCC also seeks comment on the following:

  1. Whether the data should be provided to callers in the CSV (comma-separated values) or XML (eXtensible Markup Language) format or some other format(s)?
  2. Any specific criteria or requirements that an entity must satisfy to become an eligible user of the database.
  3. Whether database users should be subject to a registration requirement.
  4. How service providers should be compensated for the costs of reporting data to a reassigned numbers database and the cost to callers to use the database.
  5. How often a caller would need to check a reassigned numbers database to avail themselves of the safe harbor?

Comments on this matter are due by June 7, 2018 and reply comments are due by July 9, 2018. Visit FCC for more information. 

BBB Helps Fight Fraud at the Front Door by Teaming with ADT and Other Security Leaders

As summer selling season kicks off, news conference with Louisiana State Fire Marshal features victims and tips on stopping deceptive sales in the security industry

Baton Rouge, LA (May 18, 2018) – Despite a downward trend in the number of home security customers victimized by fraudulent door-to-door security sales representatives, the Better Business Bureau is continuing to team with leading organizations, including The Monitoring Association, the Electronic Security Association, and ADT LLC, to educate consumers.

During a news conference hosted today by Louisiana’s State Fire Marshal, H. “Butch” Browning, BBB helped sound the alarm about deceptive sales practices.

“We applaud the industry for continuing to root out the few bad apples who practice deceptive sales and con consumers,” said Carmen Million of the Better Business Bureaus Serving Baton Rouge. “Through today’s outreach we hope to prevent more front-door fraud.”

In 2017, over 700,000 consumers across North America used BBB resources to research information about home security companies. But thousands also complained about dishonest and misleading sales pitches, or reported door-to-door scams.

jay at ADT BBB Baton Rouge Deceptive Practices event 2018

TMA Executive Director Jay Hauhn addresses the issue of deceptive practices in the security industry.

Two of those victims spoke out today and shared how unscrupulous sales reps tried to con them out of their contracts with ADT, an A+, BBB Accredited Business and National Partner.

“I was misled into signing a contract with a salesman whom I thought was representing ADT,” said 62-year-old James Bourg of Greismar, LA. “After he quickly installed a new security panel, I did my homework and found out I was duped. I cancelled the next day.”

In 2016, nearly 3,400 customers complained to ADT about deceptive sales from competitors. There were 800 less last year. While complaints are declining, ADT vows to keep fighting.

“Whether we are bringing offenders to justice in a court of law or educating consumers in the court of public opinion, ADT will continue trying to stop deceptive sales in our industry,” said P. Gray Finney, ADT Chief Legal Officer.

At today’s event, BBB shared tips for consumers who are considering a home security system (bbb.org/homesecurity), and also released advice to potential employees who are being recruited to spend their summers knocking on doors (bbb.org/alarmsales).

“We urge those who are selling security systems to abide by the BBB Standards for Trust,” said Million. “Tell the truth, honor promises, and embody integrity.”

Additional coverage:

For more than 100 years, Better Business Bureau has been helping people find businesses, brands and charities they can trust. In 2016, people turned to BBB more than 167 million times for BBB Business Profiles on more than 5.2 million businesses and Charity Reports on 11,000 charities, all available for free at bbb.org. The Council of Better Business Bureaus is the umbrella organization for the local, independent BBBs in the United States, Canada and Mexico, as well as home to its national and international programs on dispute resolution, advertising review, and industry self-regulation.


Maryland State Police’s Christopher Corea is Recipient of 2018 TMA Public Sector Award

TMA-Public-Sector-AwardFirst Sgt. Christopher Corea, Executive Officer of the Maryland State Police Information Technology Division, is the recipient of The Monitoring Association’s 2018 Public Sector Award. This special honor is given by TMA in recognition of a public sector individual’s contribution to the alarm industry. Corea will be presented with the award at the 2018 Electronic Security Expo (ESX) Public Sector Luncheon on Friday, June 22, at Music City Center in Nashville.

Corea-Christopher-FSgt“It is our pleasure to recognize Chris Corea for his tireless efforts to advance the implementation of ASAP – the Automated Secure Alarm Protocol – in the State of Maryland,” said TMA President Ivan Spector. ASAP is a technology that automates communication between alarm monitoring centers and 9-1-1 centers, resulting in improved accuracy and speed of emergency response. In March 2018, Prince George’s County, MD became the first municipality in Maryland to implement ASAP as well as the 37th nationwide to implement the service and, at 499 square miles, the second largest.

The award recipient must be nominated by one or more TMA members in good standing. TMA Past President Pamela Petrow and Past President (and current Executive Director) Jay Hauhn put Corea’s name forward for consideration.

“Implementation of ASAP in Maryland was a strategic priority for the program given its proximity to the nation’s capital,” said Hauhn. “Funding and scheduling obstacles hampered our ASAP implementation efforts in Maryland. Because of Sgt. Corea’s ability to manage through the challenges and his perseverance, Maryland’s statewide CJIS network is now ASAP capable.”

First Sergeant Corea has been with the Maryland State Police for 18 years. After graduating from Richard Stockton College of NJ with a B.S in Criminal Justice in 2000, he joined the Maryland State Police. Following graduation from the academy, he began his career patrolling 45 miles of Interstate 95 between Delaware and Baltimore City.  Throughout his time on the road, he was recognized by multiple organizations for his enforcement efforts in impaired driving.

Corea became a Drug Recognition Expert in 2004 and an instructor for the program soon after.  In 2005, he was transferred to the Information Technology Division where he began developing enterprise level applications for the State of Maryland. As he worked his way through the ranks to First Sergeant, he continued to support multiple projects and applications improving the technology being used by all law enforcement agencies in Maryland. In 2014, he became the Nlets representative for the State of Maryland where he is working on improving the use of the Nlets network for Maryland law enforcement. His work in this area including the implementation of ASAP.

ASAP-Concept1DThe ASAP service is based on an American National Standard developed jointly by the Association of Public Safety Communications Officials (APCO) International and TMA, then the Central Station Alarm Association (CSAA). The service provides a standardized method through the use of automation and the power of Nlets to deliver alarm notifications to 9-1-1 Public Safety Answering Points. The result can be an increase in the likelihood of law enforcement apprehensions for crimes in-progress and of fire quickly extinguished with minimal property damage. ASAP can be a life-saver for a medical emergency patient when every second counts.

“I am fortunate to have the opportunity to combine my passions for law enforcement and technology in my current position with the Maryland State Police,” said Corea. “Improving law enforcement response and giving officers the information they need at their fingertips has always been my goal. Being able to navigate the obstacles we had as a State and implement the ASAP protocol in one of the largest counties in Maryland is just the beginning. I look forward to many more technological advancements as a State while in my role with NLETS and the Maryland State Police.”

For more information, contact Elizabeth Lasko at TMA, 703-242-4670 or elasko@tma.us.


FCC Releases Rural Call Completion Order and Further Rulemaking

Comments are due by June 4; reply comments are due by June 19.

The FCC has released its Rural Call Completion Order (RCC Order) and Third Further Notice of Proposed Rulemaking (Third FNPRM). In the RCC Order, the FCC adopts a new rule to address rural call completion issues, including issues raised by AICC. The FCC’s rule requires “covered providers,” defined as entities that select the initial long-distance route for a large number of lines, to monitor the performance of the “intermediate providers” to which they hand off calls and holds covered providers responsible for the entire path of the call.  The FCC also requires covered providers to make available a point of contact to address rural call completion issues.

Specifically, the FCC’s rule adopted in the RCC Order provides that a covered provider, for each intermediate provider with which it contracts, shall: (a) monitor the intermediate provider’s performance in the completion of call attempts to rural telephone companies (both incumbent and competitive local exchange carriers ) from subscriber lines for which the covered provider makes the initial long-distance call path choice; and (b) based on the results of such monitoring, take steps that are reasonably calculated to correct any identified performance problem with the intermediate provider, including removing the intermediate provider from a particular route after sustained inadequate performance. This requirement entails both prospective evaluation to prevent problems and retrospective investigation of any problems that arise. The FCC also requires covered providers to take steps that are reasonably calculated to correct any identified performance problem with the intermediate provider. Although covered providers have flexibility in the remedial steps they choose so long as they pursue a solution that is reasonably calculated to be effective, the FCC specifically requires removing intermediate providers from routes where warranted.

The FCC requires covered providers to exercise oversight regarding their entire intermediate provider call path to rural destinations. However, the FCC does not cap the number of intermediate providers.

Covered providers are required to make available on their websites a telephone number and email address for the purpose of receiving and responding promptly to any rural call completion issues. The contact information must be easy to find and use. Covered providers must ensure that any staff reachable through this contact information has the technical capability to promptly respond to and address call completion concerns. The contact information must be kept current on their websites and updated with any changes within ten business days.

The FCC declines to set specific performance targets or benchmarks for call answer rates, call completion rates, or any other performance metric.

Rural Call Completion Further Rulemaking

In the Third FNPRM, the FCC seeks comment on rules to be applied to intermediate providers to address rural call completion issues and to comply with the Rural Call Completion Act (RCC Act).  Most of the proposed rules for intermediate providers follow the rule adopted for covered providers and will work in connection with that rule to prevent rural call completion issues, address issues when they occur, allow alarm industry members to identify the entities involved in call completion issues and provide a contact person to resolve any issues.

The Third FNPRM also asks for comment on service quality standards to be applied to intermediate providers.

The FCC seeks comment on the following issues:

  1. The FCC proposes to require any intermediate provider to register with the FCC, and provide its business name, primary address; the name, telephone number email address and business address of its regulatory contact and/or designated agent for service of process; all business names that the intermediate provider has used in the past; and the states in which it provides service. The FCC also proposes that a point of contact must be provided for addressing rural call completion issues including the name, title, business address, telephone number and email address of at least one contact person.
  2. The FCC proposes that a covered provider may not rely on any unregistered intermediate providers in the path of a given call.
  3. The FCC proposes that covered providers must be responsible for knowing the identity of all intermediate providers in a call path and must furnish upon request to the FCC or state authorities the identities of any or all intermediate provides in the respective call paths.

The FCC also seeks comment on service quality requirements for intermediate providers. The RCC Act requires intermediate providers that offer, or hold themselves out as offering, the capability to transmit covered voice communications from one destination to another and that charge any rate to any other entity (including an affiliated entity) to comply with “service quality standards” to be established by the Commission. In promulgating such standards, the Commission must “ensure the integrity of the transmission of covered voice communications to all customers in the United States” and “prevent unjust or unreasonable discrimination among areas of the United States in the delivery of covered voice communications.” The term “service quality standards” is not defined in the RCC Act. However, the FCC notes that “the Senate Commerce Committee Report states that such standards ‘could include the adoption of specific call completion metrics or the more general adoption of duties to complete calls analogous to those that already apply to covered providers under prior Commission rules and orders.’”

The FCC seeks comment on the following issues concerning service quality standards for intermediate providers:

  1. The FCC proposes to require intermediate providers to take reasonable steps to: (1) prevent “call looping,” a practice in which the intermediate provider hands off a call for completion to a provider that has previously handed off the call; (2) “crank back” or release a call back to the originating carrier, rather than simply dropping the call, upon failure to find a route; and (3) not process calls so as to “terminate and re-originate” them (e.g., fraudulently using “SIM boxes” or unlimited VoIP plans to re-originate large amounts of traffic in an attempt to shift the cost of terminating these calls from the originating provider to the wireless or wireline provider).
  2. The FCC states that Section 64.1601(a)(2) of the Commission’s rules already requires intermediate providers within an interstate or intrastate call path that originate and/or terminate on the PSTN to pass unaltered to subsequent providers in the call path signaling information identifying the telephone number, or billing number, if different, of the calling party that is received with a call. In addition, section 64.2201(b) requires intermediate providers to return unaltered to providers in the call path any signaling information that indicates that the terminating provider is alerting the called party, such as by ringing. The FCC asks if any additional rules are necessary to prevent intermediate providers from manipulating signaling information for calls destined for rural areas?
  3. The FCC asks whether it should require intermediate providers to temporarily or permanently remove an intermediate provider who fails to perform at an acceptable service level from the routing path, as it required for covered providers and whether it should require intermediate providers to take reasonable steps to limit the number of intermediate providers after them in the call chain?
  4. The FCC proposes to require intermediate providers to have processes in place to monitor their own rural call completion performance when transmitting covered voice communications.
  5. The FCC asks if it should adopt duties to complete calls for intermediate carriers like those that already apply to covered providers under prior Commission rules and orders?
  6. The FCC asks if it should require intermediate providers to meet or exceed one or more numeric rural call completion performance targets or thresholds while giving them flexibility in how to meet this requirement? If so, what metric(s) should be utilized and what target(s) or threshold(s) should be set?
  7. The FCC seeks comment on whether intermediate providers should be required to certify that they do not transmit covered voice communications to other intermediate providers that are not registered with the Commission.
  8. The FCC asks whether specific service quality measures for intermediate provider should be adopted. The FCC states that following adoption of rules implementing the RCC Act, covered providers who qualify for the safe harbor provisions will also be exempt from the service quality requirements of the RCC Act.
  9. The FCC asks whether an intermediate provider’s failure to comply with the quality standards or to fully and accurately register should result in removal from the registry, thereby preventing covered providers from using that intermediate provider?

Comments are due by June 4, 2018 and reply comments are due by June 19, 2018. To comment, visit FCC.


Contributed by Mary Sisak, Blooston Law Firm, TMA Counsel

Security Summit Canada: Special Offer for TMA Members for June 6 on Toronto

Security Summit Canada is a unique security conference that brings together members of Canada’s security channel to learn how to expand their business, attract new customers, retain more clients and offer more value to their customer base.

TMA is pleased to support this year’s Security Summit Canada (June 6 in Toronto) as an Industry Partner Sponsor. Presented by SP&T News, Security Summit Canada is a gathering of alarm companies and dealers, security integrators, central station owners and operators, security product distributors, security product resellers, and security consultants and specifiers, who will:

  • Learn about new recurring revenue models
  • Acquire direct insights on how to grow your security business
  • Learn how to attract new customers
  • Learn how to keep existing customers
  • Learn how to make more money
  • Learn how to protect your company from liabilities
  • Discover the latest industry trends from security experts
  • Network with fellow security professionals

TMA members are invited to attend at a special discount. Email communications@tma.us for more information. For program details, visit Security Summit Canada. 


“World’s Youngest Venture Capitalist” Will Share Insights at 2018 TMA Annual Meeting

What will the world of business look like thirty years from now? And how will the nuanced, and often misunderstood, habits of millennials shape your company’s growth? Forbes 30 Under 30 honoree and “world’s youngest venture capitalist” Alex Banayan has the answers.

Alex Banayan

Alex Banayan, author of “The Third Door,” will present How 5 Millennial Trends Will Transform the Next 30 Years of Business at the 2018 TMA Annual Meeting, October 13-17 in Palm Beach, FL.

Banayan will expound on topics ranging from the pervasiveness of artificial reality to the automation revolution in his insightful and mind-expanding presentation for TMA members. Weaving in examples from Snapchat to Tesla, Banayan will share how the products millennials are obsessed with can clue us in to the habits his generation will perpetuate over the coming decades. You’ll leave with the insights you need to better understand your millennial employees and their effect on the future of your business.

The program to date, along with registration, travel, and hotel information, is posted at TMA Annual Meeting.

Finalists for 2018 TMA Excellence Awards Announced

Four Winners to Be Revealed at ESX on June 19

VIENNA, VA (May 7, 2018) – The Monitoring Association is pleased to announce the twelve finalists for the 2018 TMA Excellence Awards. Listed in alphabetical order by company within each category, they are:

  • Monitoring Center of the Year Finalists
    ADT, Affiliated, Vector
  • Monitoring Center Operator of the Year Finalists
    Duane Hilton, ADT; Linda Reed, Dynamark; Patricia Fody, Vector
  • Monitoring Center Manager of the Year Finalists
    Shari Wilson, ADT; Carmelo Mosca, Affiliated; Bill Fisher, UAS
  • Monitoring Center Support Person of the Year Finalists
    Beth Bailey, ADT; Lamar Shroyer, Dynamark; Boris Pejic, G4S

“We congratulate our finalists for being recognized as the best of the best,” said Elizabeth Lasko, Vice President of Communications, TMA. “Our judges really had a challenging time choosing the finalists, let alone the winners, from all the nominations. Our applicants all submitted stories that clearly demonstrate the breadth of excellence in companies and individuals across our industry.”

The TMA Monitoring Center Excellence Awards recognize any FM Approvals, Intertek/ETL or UL-listed monitoring center (TMA members and non-members) and outstanding personnel who perform in the highest professional manner, thereby making a significant contribution to the betterment of the alarm industry and the alarm profession while demonstrating exceptional service to their customers and community.

The purpose of the awards program is to:

  • Establish and promote the inherent value of professional monitoring services in general.
  • Honor those who have made the most significant contributions to the service.
  • Promote the distinct level of professionalism attained by NRTL-approved monitoring centers.

The TMA Monitoring Center Excellence Awards are co-sponsored by SDM Magazine, which will publish a feature story on the winners later this summer. Entries are judged by a blue-ribbon volunteer judging panel appointed by TMA. The four winners will be announced at the Opening Reception of the 2018 Electronic Security Expo (ESX) on Tuesday, June 19. For past winners and more information, visit www.tma.us.