WPC 2BJ Z Courier#|x2x6X@`7X@HP LaserJet 4_230_1HPLAS4.PRS 4x  @\_)^@2s6FZu#|xCourierTimes New Roman Boldoman (Bold) (TT)HP LaserJet 4/4MtScript ROOM 224HPLAS4.WRSSx  @,,P@X01Í ÍX01Í Í2KXK?K "i~'^DOuuOOOu=O=AuuuuuuuuuuOOuۨYuۨ騨OAOuOuggOuAOAăugYOuuug]3]yO=yOOO=OOOOOOuOAuuuuu騨gggggVAVAVAVAuuuuuuuuuuuuuggyggggguuuyuYAYYOYyyAiO]Auu稨gggYYYywO騨ygggOYOu=uuN?NWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNTT|uOuuuuuuFOuFOuFOOuuuPPuu鏱T錌TƒOuuF"u錊~u匌u<?xxx,2x6X@`7X@@ND,4  pG;3g>6,H0g4  pG;0@ND,4  pG;NNuuNuNFtN捍:]@suuCzsffz;NuuANNu;N;AuuuuuuuuuuNNu٩[uܩ驩NANuNuggNuANA‚ug[Nuuug\4\yNuuuuNN鵵NNuuRuN[N;Nuuuu4uNFuNu]FFN~;NFMuu驜[[[[uuuuuugggggAAAAuuuuuuuu"i~'^6?i]]???]i1?14]]]]]]]]]]??iii]{{tG]{ti{{?4?l]?]iRiR?]i4?i4i]iiRG?i]]]RK)Ka?1al???1??????]?i4]]]]]R{R{R{R{RE4E4E4E4i]]]]iiii]]i]]]]ri]]]RRaR{R{R{R{R]]]a]ilG4GiG?Giiaai{4{T{?{K{4iii]]RRRiGiGiGia{_{?{liiiiiia{R{R{Ri{?iiG{?]1]]>2>WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNCppCc]?]]]]]]8?]8?]8??]]]@@p]]rCppCvii?]]8"{{{{]pne]ipp]/>h]]4>>]j/>/4]]]]]]]]]]>>jjj]}}rI]}rh}}>4>l]>]hShS>]h4>h4h]hhSI>h]]]SJ)Ja>]]]]>h>>>]]A]>I>/>]]]])]>8]j>]Kf88>le/>8=]]}}}}IIIIjrh]]]]]]SSSSS4444]h]]]]]f]hhhh]h"i~'^DOuuOOOu=O=AuuuuuuuuuuOOuۨYuۨ騨OAOuO{{tG]{ti{{]3]yO=yOOO=OOOOOOuOAuuuuu騨gggggVAVAVAVAuuuuuuuuuuuuuggyggggguuuyuYAYYOYyyAiO]Auu稨gggYYYywO騨ygggOYOu=uuN?NWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNTT|uOuuuuuuFOuFOuFOOuuuPPuu鏱T錌TƒOuuF"u錊~u匌u;NuuANNu;N;AuuuuuuuuuuNNu٩[uܩ驩NANuNuggNuANA‚ug[Nuuug\4\yNuuuuNN鵵NNuuRuN[N;Nuuuu4uNFuNu]FFN~;NFMuu驜[[[[uuuuuugggggAAAAuuuuuuuu2QKcW"i~'^:DpddȨDDDdp4D48ddddddddddDDpppd|Ld|pȐD8DtdDdpXpXDdp8Dp8pdppXLDpdddXP,PhD4htDDD4DDDDDDdDp8dddddȐXXXXXJ8J8J8J8pddddppppddpddddzpdddXXhXXXXXdddhdptL8LpLDLpphhp8ZDP8pppddƐXXXpLpLpLphfDtppppppȐhXXXpDppLDd4ddC6CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxHjdDdddddd6,H0g4  pG;0@ND,4  pG;7nC:,4Xn4  pG;X<r5ddd,Oed6X@`7@pCvii?]]8"{{{{]pne]ipp]$// Letter, Oncor v. ACUTA, File IC9415325, DA 95432 //$ $/ 0.291 Delegated authority /$ ///newjob///  ?X<$///DA 95432 3795///$@  a <b  4 pW; Federal Communications Commissionă  a*< Xn4 pW;4 Washington, D.C. 20554 d  @7Oe у  ?4<#x6X@`72X@#  March 6, 1995 Released: March 9, 1995 Mr. Greg Casey Senior Vice President Oncor Communications, Inc. 6707 Democracy Boulevard Bethesda, Maryland 20817 Dear Mr. Casey: xThis is a letter of admonition issued to Oncor Communications, Inc. (Oncor) in connection with the informal complaint filed by Mr. Randal Collett of the Association of College and University Telecommunications Administrators (ACUTA) (File No. IC9415325). In his complaint, Mr. Collett states that Oncor is promoting a service whereby an individual dials the Oncor access code (10658), plus 0, and then a Canadian number to reach an information provider. According to the complainant, no operator asks for billing information, and the call is apparently billed to the originating telephone on the basis of Automatic Number Identification (ANI). Mr. Collett states that this situation has the potential to be financially disastrous to the ACUTA members, who allow students to use 10XXX0+ access to their long distance carriers. xThe Enforcement Division's staff served ACUTA's letter on Oncor. Your company responded on November 16, 1994 and did not dispute the availability of the calling sequence that Mr. Collett described. Oncor states that a consumer who wishes to place an international call over Oncor's network would dial 10 "followed by Oncor's access code of 6580...." Oncor's response states that this access method "is designed for direct dialed calls by residential subscribers." The letter, however, does not address the concern raised by Mr. Collett regarding calls from aggregator locations, other than an offer by Oncor to block calls at the subscriber's request. For the reasons set forth below, we conclude that Oncor's procedure for handling 10XXX0+ calls is inconsistent with the Commission's rules and policies regarding operator services and toll fraud. xIn CC Docket No. 9135, the Commission required aggregators to selectively unblock 10XXX access codes so that consumers could"$)0*0*0*1"  ?<use this dialing sequence to reach interexchange carriers. See Policies and Rules Concerning Operator Service Access and Pay  ?<Telephone Compensation, Report and Order and Further Notice of Proposed Rulemaking, 6 FCC Rcd 4736 (1991). Aggregators were allowed to block 10XXX dialing sequences that always result in billing to the originating telephone, such as 10XXX1+, but were required to unblock 10XXX calls that are delivered to a carrier's operator services. Traditionally, 10XXX0+ calls have resulted in interception by the carrier's operator to determine how the call should be billed, and to observe any billing restriction codes that are delivered with the call. The Commission subsequently delayed in part the 10XXX unblocking requirement to ensure that aggregators were not exposed to toll fraud associated with selectively unblocking 10XXX access. By using a nonindustry standard for handling 10XXX0+ calls, however, Oncor has thwarted the Commission's efforts to unblock 10XXX access in a way that is readily understandable and fair to both consumers and aggregators. xThe provision of 106580+ access without operator interception, with the cost of the call billed to the originating number, is an invitation to toll fraud from aggregator locations. As you know, the Commission has concluded that carriers have an obligation to prevent toll fraud. In cases where the carrier was in the best position to prevent fraud but failed to take reasonable steps to prevent the fraudulent calls, the Commission will not impose liability on the subscriber of the originating  ?<phone. Cf. United Artists Payphone Corp. v. New York Tel. Co.  ?<and American Tel. & Tel. Co., 8 FCC Rcd 5563, 5566 n.44 (1993) (carriers must take appropriate action to prevent fraudulent calling). It is not sufficient for Oncor to offer to block 10XXX0+ calls from individual aggregator locations at the request of the aggregator. The obligation on Oncor in the first instance is to comply with the Commission's efforts to prevent toll fraud by taking reasonable preventive steps before the fraudulent calls are made. In this case, that obligation is not to bill 10XXX0+ calls using ANI. It is an unreasonable practice to require all aggregators to conform to Oncor's nonstandard access arrangement, with blocking of that access available only on request. xAccordingly, Oncor is directed to immediately stop allowing 10XXX0+ calls to be billed to the originating telephone, and, for such calls, to immediately implement operator intervention that will obtain billing information by means of a valid calling card. Please respond within five days of the date of this letter confirming Oncor's compliance with this requirement. x` `  hh@hSincerely, x` ` x` `  hh@hGregory A. Weiss x` `  hh@hActing Chief x` `  hh@hEnforcement Division"h)0*0*0*1"Ԍx` `  hh@hCommon Carrier Bureau cc: Randal CollettT