CALL DELIVERY SYSTEMS LEGAL COMPLIANCE

FCC Telephone Carrier Regulations

(MIDI™ Calls & Intercept Messages)

An intercept message is a recorded message that a telephone carrier may choose to play that informs the caller that their call could not be completed as dialed.

Based on our telecom legal council’s extensive FCC research, discussions with the FCC staff in the Competition Policy Division, Wireline Competition Bureau and review of the FCC’s miscellaneous rules on common carriers (47 CFR Part 64) we conclude the following:

Forwarding MIDI Calls: We are not aware of any FCC rules that disallow carriers from forwarding MIDI™ Calls to third parties such as research surveys or a company promoting a product or service. MIDI is an acronym for “Misdialed, Incomplete or Disconnected Inbound”

Intercept Message: We are not aware of any FCC regulations requiring carriers to provide intercept messages for MIDI™ Calls, other than non-emergency numbers, as stated below:

• 64.3004. Obligation for providing an intercept message for disconnected emergency numbers. Upon termination of permissive dialing, as provided under §64.3003, telecommunications carriers shall provide a standard intercept message announcement that interrupts calls placed to the emergency service provider using either a seven or ten-digit emergency number or an abbreviated dialing code other than 911 and informs the caller of the dialing code change.
• For those carriers that choose to provide intercept messages, other than with non-emergency numbers, we are not aware of any FCC regulations specifying the actual language, other than the generally accepted business practice that messaging to the public be clear and accurate.

These findings and are intended to be informative and should not be relied on as a legal opinion.