By Peter Farmer
Many of you know of my dual-nationality. Being both British and Canadian, means I give twice as much grief to Americans (and get twice as much back) as the average person. The French too, but that’s a different story.
At Simwood, we’ve always tried to champion the consumer and the thriving value chain that serves them, in either of our domestic markets.
But the USA (by which I really mean the seemingly regulatory-endorsed oligopoly there) market is slowly losing the plot.
No-one likes scrotes that target little old ladies. We can all agree they need to take long walks off short piers in shark infested waters. But no-one likes long rambling voicemails either.
Our tea-party loving brethren are approaching this issue with penalties at the terminating end based on traffic profiles. More than 1% under or equal to 6 seconds ? Penalty. More than 15% under a minute? Penalty.
For those who are not experts in ASRs, NERs, ACDs and whatnot – allow me to translate.
- Don’t leave a voicemail? Penalty if you do it more than 1 in 100 calls.
- Do leave a voicemail but don’t ramble on? Penalty if you do that more than 1 in 7 calls.
- Are you a concierge who spends their days saying “Your taxi is here, Mr. Farmer”? To the gallows with you.
- Or maybe you’re just a dutiful family person. “Hey honey, just leaving the office, be home in 20.” Dear Lord, it’s the SuperMax for you.
Of course, these metrics are good indicators of malevolence, yet they are not determinative. Imagine a hospital confirming appointments for the coming week, and compare and contrast that call profile with someone selling extended warranties. They will likely be identical.
This is where the USA has lost its way. By looking solely at the metrics (whereas the UK and Ireland to name a few are more into looking at the use case as well) it risks reinforcing the oligopoly. We’ve talked about this risk before, in the context of STIR/SHAKEN, but it’s worth calling out these metrics too.
If you’re a major global Goliath, putting even the most prolific dialler on your network will barely move the needle of your ACD and ASR. If you’re a new entrant or a niche player, that same dialler will overwhelm all of the other traffic on your network and result in the economic equivalent of a lynching.
What’s the upshot? Dialler traffic still has a home, just at a premium on major networks. If the FCC were bound by the same rules as the 27 EU member states and the UK, that paradigm would be open to legal challenge.
Simwood and like-minded peers are engaged on this topic and trying to find a way forward. In the meantime, as Simon recently posted we are taking a defensive position on our US rates with a 30/6 billing default. Conversations can get that varied, but given the above, you’ll not be surprised to learn terms and conditions apply.
And while I am expecting many chirps of “limey Canuck” to be sent my way, on this one, I’m sure, everyone can see the problems and risks.
