DNO And DNC Lists - Everything Carriers Should Know
Do-Not-Originate (DNO) and Do-Not-Call (DNC) lists have existed for some time now. The implementation of DNC lists is more common compared to DNO lists but that is set to change.
The Federal Communications Commission (FCC) in its latest order has mandated the implementation of a reasonable DNO list for all the carriers and gateway providers handling traffic coming into the USA.
The move comes in line with the FCC’s objective of Targeting and Eliminating Illegal Robocalls and Scam calls.
When paired up with the earlier initiative of STIR/SHAKEN, implementation of a reasonable DNO list promises to severely mitigate the risk of illegal robocalls.
If you’re a carrier or gateway provider wondering what all of this is or how it works, you’re in the right place.
We will be covering all vital pieces of information so you know what steps need to be taken.
What Is A Do-Not-Call List?
A Do-Not-Call (DNC) list is a registry of phone numbers of users who have opted out of receiving any form of telemarketing calls. As per common regulations adopted globally, all registered telemarketing firms are required to comply with the DNC list.
DNC lists are required to be followed and enforcement of these is handled by a designated government agency. For the USA, it's the Federal Trade Commission (FTC), for India it is the Telecom Regulatory Authority (TRAI), for the UK it's the Office of the Information Commissioner and so on.
These authorities have the power to impose fines on violators or terminate their licenses or both. These DNC lists are maintained and updated regularly and provided to telemarketing firms for them to comply with it.
What Is A Do-Not-Originate List?
A Do-Not-Originate list contains phone numbers that are either invalid, unallocated, allocated but unused and numbers used for inbound only traffic. A carrier or a gateway provider are required to block any calls originating from any numbers in the DNO list.
Scammers usually resort to Caller ID and Identity spoofing to place robocalls impersonating legitimate businesses and authorities.
For example, a scammer may resort to using an inbound calls only number of a bank to place robocalls and scam customers. By implementing a DNO list, all such calls originating from an inbound calls only number are blocked by carriers and gateway providers.
Another example would be a scammer using a phone number issued to a business which remains unused by them. Even in this scenario, the DNO list implementation will result in any such calls being blocked.
Now that we know what a DNO list is, we can head on to learning what all types of numbers are included in it.
Types Of Numbers To Be Included In A DNO List
The FCC has set a clear outline for the type of numbers to be included in any reasonable DNO. Accordingly, the following four types of numbers are to be included:
- Inbound Calls Only Numbers - Phone numbers that a subscriber, business or authority has assigned to be used only for inbound calls.
Example - A customer support number for a Bank, helpline numbers for various essential and emergency services, etc.
- Invalid Numbers - North American Numbering Plan (NANP) numbers that are invalid.
- Unallocated Numbers - Valid North American Numbering Plan numbers that are valid but haven’t been allocated to any provider by the (NANP) Administrator.
- Unused Numbers - Valid and allocated numbers that are unused and so confirmed by the subscriber or provider.
The FCC has not issued an official DNO list from their end. They expect the gateway providers to compile a reasonable DNO list by themselves, based on the above recommendations.
Why Is FCC Mandating Implementation Of DNO lists?
The FCC wants to step up its efforts to combat the threat of illegal robocalls and scams resulting out of those. The first step in this process was the introduction and implementation of STIR/SHAKEN.
STIR/SHAKEN is quite effective in its own right. However, it still leaves a few opportunities that scammers can exploit. The planned implementation of the DNO lists by the gateway providers is set to eliminate such opportunities.
When a gateway provider or a carrier implement a DNO list, any calls originating using numbers in the DNO list are blocked right away. Thus, all traffic originating outside the USA automatically filters out any potential scam calls.
Important Things To Know For Carriers and Gateway Providers
The Deadline for Implementation
On November 18, 2022, the FCC announced the deadline for implementing a reasonable DNO list through the Federal Register Vol. 87, No. 222. As per the announcement the deadline was set at December 19, 2022.
We are well past the deadline as I write this article. In case you have not yet implemented a reasonable DNO list, do it at the earliest.
Consequences For Not Complying
- Entities / Gateway Providers will be imposed with fines for failures to block calls on a per-call basis.
A fine amounting to a maximum of $22,021 will be imposed upon Uncommon Carriers for each violation.
A fine amounting to a maximum of $220,213 will be imposed upon Common Carriers for each violation.
- Entities / Gateway Providers will be imposed with maximum permissible fine for failures to appropriately certify in the Robocall Mitigation Database.
- The Commission will be notified when a known bad actor files for a new certification and thus, resultantly will be delisted from the Robocall Mitigation Database.
- Repeat Offenders will have their section 214 operating authority revoked. The owners, directors, officers or principals of these repeat offenders will be banned from any future association with any entities regulated by the Commission.
Putting Together a DNO List
As stated earlier, the FCC won’t be issuing any official DNO list. Instead all gateway providers are required to prepare one based on the guidelines provided.
How should you go about creating a DNO list? Here is how.
Step 1 - Gather all Inbound Only Numbers
You can either opt for telephone directories or online databases to procure all the important numbers used for inbound calling only.
Step 2 - Gather Invalid, Unallocated and Unused Numbers
You can either opt for any available online database or rely on a third party provider for this list.
Step 3 - Compile a DNO List
Once you have sufficient numbers, you can proceed and compile a DNO list. As long as it’s put together using FCC guidelines, you’re good to go.
Step 4 - Regularly Update DNO List
This DNO list needs to be updated regularly to ensure new additions are made as required. Newly allocated and numbers which were previously unused should also be removed from the list to keep it accurate.
DNO List for ConnexCS Customers
ConnexCS has been working on finalizing a DNO list since the announcement. Our list is ready to be offered to our customers in its base form. It was compiled strictly based on FCC recommendations.
We’re making some final additions to the list from our end to ensure our DNO list performs better than industry standards. All customers shall be informed as soon as the list has been finalized.
Instructions pertaining to implementing it through our platform will be conveyed to customers in due time.