The FCC has released a Third Report and Order and Order (Order) that establishes, as directed by the Improving Rural Call Quality and Reliability Act of 2017 (RCC Act), a registry for intermediate providers and requires intermediate providers to register with the Commission before offering to transmit covered voice communications. Additionally, the Order requires covered providers to not only use registered intermediate providers to transmit covered voice communications on an exclusive basis, but also to maintain the capability to disclose the identities of any intermediate providers relied on in the call path to the Commission, if requested. Finally, the Commission, in this Order, adopts a narrowly tailored exception to its rules in instances of force majeure. The RCC Act also requires the Commission to address the issue of intermediate provider “service quality” on or before February 26, 2019. To that end, the Commission released a Third Further Notice of Proposed Rulemaking, with comments due earlier this summer. For years, rural call completion has been a huge issue for rural telecommunications carriers, and this problem was magnified when the FCC fined T-Mobile $40 million for using false ring tones in an effort to mask the use of poor quality intermediate providers.
