State Anti-Slamming Rules Report

Questions of the Day

While there have been a few tweaks around the edges in the slamming rules, not that much has changed. That gives us the opportunity to address the application of the rules to the brave new worlds of VOIP and WLNP.

Let's start with VOIP. Does a carrier need to verify a VOIP order? (One of our erstwhile competitors has been arguing "yes" for some time, without making any qualifications of that claim.)

While we like getting paid as much as the next TPV provider - ok, we do charge less than they do - honesty and common sense requires that we point out the subtleties of the VOIP situation.

Since the FCC declared that VOIP is an information service, by itself it's exempt from the anti-slamming rules. So a customer who, for example, orders a separate VOIP line - without a number portability request - does not need to have that order verified under the anti-slamming rules.

On the other hand, if customers want to keep their existing numbers, we think that's a change to their telephone service, and therefore subject to the anti-slamming rules. The number is a key part of the service. After all, moving a telephone number from one service provider to another is going to create as much or more havoc with a customer as just about any change you could imagine.

And since many customers will want to move their existing number to their VOIP service, we expect that most VOIP carriers will want to verify at least the porting of the number, which is, in fact, what we're seeing.

So what about WLNP - wireless local number portability? There's a specific exemption in the FCC's anti-slamming rules for radio-based services, so again, cell phone and PCS services - by themselves - are exempt. And again, if the cell phone carrier puts in an order to move the customer's landline number to their cell phone service, we think that's a change to the landline service, and subject to the verification requirements.

Brave New World

It doesn't take a genius to figure out where all this is headed. The battleground for service competition will be the customer's telephone number (or whatever replaces it, eventually). It's entirely conceivable that consumers will move their numbers from conventional landline service, to VOIP, to cell phone service, and someday to a WIFI/VOIP or even VOIP/cell phone hybrid. And if carriers can just submit orders to each other requesting that the number be moved from Service A to Service B without a way to verify the customer's wishes, there's a serious risk of trouble.

Of course, we know from history that if the verification process is left to the carrier, that's also a formula for problems, since carriers don't like to lose customers. Incumbent carriers can use their role in a verification process to slow down a service change, get the customer to change their mind or even do a reverse slam.

So we think the role of the anti-slamming rules is limited to number changes, not VOIP or wireless orders per se, regardless of what our competitors might tell you. But that's going to be a pretty big role as consumers get more and more comfortable with number portability and LNP services grow. And since Third Party Verification is already proven as the most cost-effective method of both preventing slamming and insuring that customer orders get processed, you can count on VoiceLog being there to help you with your verification needs.

About VoiceLog

VoiceLog LLC is the world leader in Third Party Verification and Call Recording services with almost 300 clients in the telecommunication, cable, utilities, financial services and retail industries in the US, Canada and Western Europe. Recording over 40 million calls per year, VoiceLog offers Third Party Verification, VirtualLogger™ Call Center Recording and Quality Monitoring and Third Party Quality Monitoring services.

For more information about VoiceLog, contact Larry Leikin at 410-647-4384 or lleikin@voicelog.net or visit us on the web at www.voicelog.com.

VoiceLog is a registered trademark and VirtualLogger is a trademark of VoiceLog LLC.

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