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Misuse of Internet Protocol (IP) Relay Service

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Released: May 17, 2013
Federal Communications Commission
Washington, D.C. 20554
‘ May 17, 2013

DA 13-1158

Small Entity Compliance Guide

Misuse of Internet Protocol (IP) Relay Service –

Elimination of the Guest User Program

FCC 12-71
CG Docket No. 12-38
CG Docket No. 03-123

This Guide is prepared in accordance with the requirements of Section 212 of the
Small Business Regulatory Enforcement Fairness Act of 1996. It is intended to
help small entities—small businesses, small organizations (non-profits), and
small governmental jurisdictions—comply with the new rules adopted in the
above-referenced FCC rulemaking docket(s). This Guide is not intended to
replace the rules and, therefore, final authority rests solely with the rules.
Although we have attempted to cover all parts of the rules that might be
especially important to small entities, the coverage may not be exhaustive. This
Guide may, perhaps, not apply in a particular situation based upon the
circumstances, and the FCC retains the discretion to adopt approaches on a case-
by-case basis that may differ from this Guide, where appropriate. Any decisions
regarding a particular small entity will be based on the statute and regulations.

In any civil or administrative action against a small entity for a violation of
rules, the content of the Small Entity Compliance Guide may be considered as
evidence of the reasonableness or appropriateness of proposed fines, penalties or
damages. Interested parties are free to file comments regarding this Guide and
the appropriateness of its application to a particular situation; the FCC will
consider whether the recommendations or interpretations in the Guide are
appropriate in that situation. The FCC may decide to revise this Guide without
public notice to reflect changes in the FCC’s approach to implementing a rule,
or to clarify or update the text of the Guide. Direct your comments and
recommendations, or calls for further assistance, to the FCC’s Consumer

1-888-CALL-FCC (1-888-225-5322)

TTY: 1-888-TELL-FCC (1-888-835-5322)

Fax: 1-866-418-0232


In the First Report and Order in CG Docket Nos. 12-38 and 03-123, the Commission took action
to curb the misuse of the Internet Protocol Relay Service (IP Relay) by:
 Prohibiting IP Relay providers from handling non-emergency calls made by new IP Relay
registrants prior to taking reasonable measures to verify their registration information.


1. Background Information: Definitions
 Telecommunications Relay Services (TRS) is defined as telephone transmission services that
provide the ability for an individual who is deaf, hard of hearing, deaf-blind, or who has a
speech disability to engage in communication by wire or radio with one or more individuals.
 Internet Telecommunications Relay Services (iTRS) means certain TRS in which an
individual with a hearing or speech disability uses an Internet connection with a
communications assistant (CA) to make calls. It includes video relay service (VRS), Internet
Protocol (IP) Relay, and IP captioned telephone service (IP CTS).
 iTRS Directory is the database administered by the TRS Numbering Administrator, the
purpose of which is to map each Registered Internet-based TRS user’s North American
Numbering Plan telephone number to his or her end device.
 Internet Protocol Relay Service (IP Relay) is a form of text-based iTRS that uses the Internet
to allow individuals with hearing and/or speech disabilities or who are deaf-blind to
communicate with other individuals. In an IP Relay call, the communication between the
person with a disability and the provider’s CA is conveyed in text via an Internet connection,
and communication between the CA and the receiving party is conveyed over the public
switched telephone network.
 Video Relay Service (VRS) is a form of iTRS that uses video to allow a person with a
hearing or speech disability who uses sign language to communicate with voice telephone
users through a CA.
 Interstate TRS Fund is the Fund into which contributions from all interstate
telecommunications carriers and VoIP providers are made for the support of interstate TRS,
including iTRS. Those contributions are based on the carrier’s or provider’s annual interstate
revenues from all end-user subscribers. TRS users do not pay directly for their use of TRS.
The Interstate TRS Fund is administered by the TRS Fund Administrator, currently Rolka,
Loube, Saltzer Associates (RLSA), which uses the money in the Fund to compensate eligible

TRS providers for the costs of providing the various forms of interstate TRS in compliance
with the Commission’s rules and orders.
2. Background
In 2006, the Commission initiated a rulemaking proceeding to address the misuse of IP Relay
and VRS.1 The Commission noted in the Further Notice of Proposed Rulemaking (2006
FNPRM) that it was concerned that people without a hearing or speech disability were taking
advantage of the anonymity of the IP Relay service by calling merchants to place orders using
fake, stolen, or otherwise invalid credit cards. Such abuse drains the Interstate TRS Fund and
harms legitimate consumers whose calls are rejected by individuals and businesses that have
been the victims of such misuse. In the 2006 FNPRM, the Commission sought comment on ways
to curb this abuse, including whether to adopt requirements for user registration and rule changes
that would permit relay providers to screen and terminate such calls.
In 2008, as part of the implementation of the numbering system for assigning a ten-digit
telephone number to each user of IP Relay and VRS, the Commission adopted a Second iTRS
Numbering Order, directing IP Relay and VRS providers to “implement a reasonable means of
verifying registration and eligibility information,” including the consumer’s name and mailing
address, before issuing a ten-digit telephone number to each new or existing user of these
services.2 The Order also directed providers to include in their verification procedures a
requirement for consumers to self-certify that they have a medically recognized hearing or
speech disability necessitating their use of TRS.
In a Public Notice released in 2009, the Commission reminded providers that, under the Second
iTRS Numbering Order, each provider must handle calls from newly registered users
immediately, even if the provider had not fully completed the process of verifying the caller’s
information, assigning the caller a new ten-digit number, and provisioning that number to the
iTRS database.3 The Public Notice did not eliminate the requirement for providers to implement
a reasonable process for verifying registration information provided by new users. However, it
stated that “to the extent technically feasible, Internet-based TRS providers must allow newly
registered users to place calls immediately,” even before the verification of such individuals, in
order that IP Relay users not be cut off from service during the transition to the new ten-digit
numbering and registration system. Under this “guest user” program, providers gave users ten-

1 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities; Misuse of Internet Protocol (IP) Relay Service and Video Relay Service
, CG Docket No. 03-123,
Further Notice of Proposed Rulemaking, 21 FCC Rcd 5478 (2006) (2006 FNPRM).
2 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities; E911 Requirements for IP-Enabled Service Providers
, CG Docket No. 03-123, CC Docket No. 98-57,
WC Docket No. 05-196, Second Report and Order and Order on Reconsideration, 24 FCC Rcd 791, 809-10, ¶¶ 37-
38 (2008) (Second iTRS Numbering Order).
3 Consumer & Governmental Affairs Bureau Reminds Video Relay Service (VRS) and Internet Protocol (IP) Relay
Service Providers of their Outreach Obligations and Clarifies their Call Handling Obligations for Unregistered
Users after the November 12, 2009, Ten-Digit Numbering Registration Deadline
, CG Docket No. 03-123, WC
Docket No. 05-196, Public Notice, 24 FCC Rcd 12877, 12878-12879 (CGB 2009).

digit telephone numbers and provisioned these numbers to the iTRS directory even if the
provider had not fully completed the process of verifying the users’ information. These numbers
were allowed to remain valid for the purpose of making IP Relay calls until the users’ identifying
information was authenticated or rejected.
In 2011, the Commission released a Report and Order and Further Notice of Proposed
Rulemaking adopting several additional measures to combat IP Relay fraud and abuse, including
a requirement for all TRS providers to submit to Commission-directed audits, a mandate for
iTRS providers to retain, for five years, call detail records and other records supporting claims
for payment, whistleblower protection rules for provider employees and contractors, and a
requirement that a senior executive of each TRS provider certify, under penalty of perjury, to the
validity of minutes and data submitted to the TRS Fund administrator.4
Nevertheless, concerns remain over IP Relay providers’ potentially lax methods of verifying
registration and eligibility information submitted by users and over the misuse of the guest user
program. The Commission therefore issued a Public Notice on February 13, 2012, seeking to
refresh the record initiated by the 2006 FNPRM on matters pertaining to IP Relay misuse.5
3. Rule Requirements
In this First Report and Order, the Commission determined that a prohibition against temporary
authorization of IP Relay users is necessary in order to curb the fraud and abuse that has resulted
from misuse of the temporary authorization procedure (also known as the “guest user program”).
The Order eliminates the “guest user” program and prohibits granting such temporary
authorization for any IP Relay calls other than emergency calls to 911 services. Specifically, the
Order states that:
 IP Relay providers are not permitted to deem the user as “registered” for the purposes of the
rules and are prohibited from handling the user’s IP Relay calls other than 911 emergency
calls, assigning the user a ten-digit telephone number, or provisioning such number to the
iTRS Directory. until an IP Relay provider verifies the new IP Relay user’s registration
information in accordance with the Commission’s standards; and
 IP Relay providers are expected to periodically review the ten-digit numbers that they place
in the iTRS Directory in order to delete numbers that have been assigned to users that
ultimately are not “registered” or that are otherwise associated with fraudulent calling

4 Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, Report and Order and
Further Notice of Proposed Rulemaking, 26 FCC Rcd 5545 (2011).
5 Consumer & Governmental Affairs Bureau Seeks to Refresh the Record Regarding Misuse of Internet Protocol
Relay Service
, CG Docket Nos. 12-38 and 03-123, Public Notice, DA 12-208 (rel. Feb. 13, 2012).

The Commission concluded that this rule prohibition will ensure that only verified users have
active numbers and will prevent ineligible users from using the services of other providers who
are unaware of a default provider’s ultimate decision to reject user authorization.


This decision does not impose any new reporting or record keeping requirements.


The new requirements do not impose a new regulatory and financial impact on small businesses,
but are minimizing significant economic impact on small entities. As an initial matter, there were
four entities currently offering IP Relay, and one of these has exited from this market. Of the
three that remain, there is only one small entity, and this entity supported the rules in its
comments. IP Relay providers are already required to refuse IP Relay service to unqualified and
unregistered individuals. Although, the instant decision changes the application of existing
compliance requirements by eliminating the guest user program, it does not impose new
compliance requirements on small entities. IP Relay providers are being compensated for the
provision of the service, including the costs of compliance. In addition, the decision minimizes
the economic impact of the IP Relay service on small entities conducting business over the
telephone. Indeed, by reducing misuse of IP Relay, the new requirements lessen an adverse
economic impact on small businesses merchants that accept orders over the telephone because
these merchants will be protected against unqualified and unregistered individuals who use the
anonymity of IP Relay to order merchandise using stolen or false credit cards.


 First Report and Order – FCC 12-71

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