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15 Mitel Regulatory Bulletin for Kari's Law and Ray Baum's Act Mitel Regulatory Bulletin: Kari’s Law and Ray Baum’s Act Contents Kari’s Law and Ray Baum’s Act .......................................................................................................... 3 Kari’s Law ............................................................................................................................................ 3 Information for Mitel Partners and Customers ................................................................................. 3 Ray Baum’s Act ................................................................................................................................... 4 Mitel Product Information ..................................................................................................................... 4 Mitel Cloud Solutions ........................................................................................................................... 4 MiCloud Connect .............................................................................................................................. 4 MiCloud Flex .................................................................................................................................... 4 Mitel On-Site Solutions ........................................................................................................................ 5 MiVoice Business ............................................................................................................................. 5 MiVoice Connect .............................................................................................................................. 5 MiVoice Office 400 ........................................................................................................................... 5 Frequently Asked Questions ............................................................................................................... 6 3 Kari’s Law and Ray Baum’s Act Mitel is pleased to provide our partners and customers with this bulletin containing general educational information about Kari’s Law and Ray Baum’s Act, as well as Mitel product information. Kari’s Law Kari’s Law, which comes into effect on Feb 16, 2020, places obligations on multiline telephone system (“MLTS”) manufacturers, importers, lessors, installers, managers, and operators. Kari’s Law is implemented by rules set out in FCC 19-76, which was released in August 2019. Persons who manufacture, import, sell, and/or lease a MLTS must ensure that the MLTS software/hardware includes a setting that, when turned on, enables users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the Public Switched Telephone Network (PSTN). Persons who install, manage and/or operate a MLTS must configure the MLTS’ settings so that once installed the MLTS is fully capable of: (i) a user dialing 911 directly from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN; and (ii) sending 911 call notifications to a central location at the facility where the system is installed or to another person or organization at a different location (e.g. central or other location) if the MLTS is capable of doing so without an improvement to the hardware or software of the system. FCC 19-76 does not prohibit indirect dialing of 911 (e.g. 9911) provided that direct 911 is enabled. Information for Mitel Partners and Customers Mitel is typically the installer, manager and operator (the operator role is typically shared with customer) of its retail cloud solutions. Mitel partners or customers are typically the installer, manager and/or operator of partner delivered plus (or wholesale) cloud MLTS solutions and on-premise MLTS solutions. FCC 19-76 details specific 911 call notification requirements. Both these requirements, and Mitel product documentation, should be reviewed carefully by any person engaged in the business of installing, managing and/or operating an MLTS prior to installation and/or operation. Mitel recommends that partners and customers installing, managing or operating a partner delivered plus cloud MLTS or on-premise MLTS ensure that they have a clear understanding of our technology and obtain independent legal advice in respect of Kari’s Law. Mitel recommends upgrading systems which do not comply with Kari’s Law as a best practice. However, Kari’s law is prospective only and does not require upgrading such systems if they are already in existence as of Feb 15, 2020. However, after Feb 16, 2020, independent legal advice should be obtained prior to upgrading (or increasing the capacity of) any non-compliant systems deployed prior to Feb 15, 2020 as these actions may trigger Kari’s Law requirements. 4 Ray Baum’s Act Ray Baum’s Act requires the FCC to conclude a proceeding to adopt rules to ensure that a “dispatchable location” is conveyed with 911 calls regardless of the technological platform used, including MLTS. The FCC conducted such a proceeding and the resulting order, FCC 19-76, was released in August 2019. FCC 19-76 lays out new "dispatchable location" rules for which the compliance dates are January 6, 2021 for on-premise fixed devices, January 6, 2022 for on-premise non-fixed devices, and January 6, 2022 for off-premise devices. Mitel is currently reviewing these new requirements. Mitel Product Information Mitel Cloud Solutions MiCloud Connect Retail United States MiCloud Connect deployments enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN. At this time, MiCloud Connect does not support notice to a central (or other location) when 911 is dialed. Such notice is not required as configuring it would require a software or hardware improvement, however, Mitel is currently developing a feature to support notification. MiCloud Flex Retail United States MiCloud Flex deployments enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN. As of Feb 16, 2020, phone and console-based 911 alerts consisting of a visual display and a tone will be enabled on all new retail MiCloud Flex deployments in the United States. Alerts will be delivered to up to 32 phones and consoles chosen by the customer. The alert, which contains the time and date of the call, the caller’s internal extension number as well as a configurable description of the caller, is initiated contemporaneously with a 911 call, and does not delay the call. Mitel recommends that 911 alerts be enabled in all Flex deployments. Retail customers with deployments pre-dating Feb 16, 2020 in which are alerts are not enabled should contact Mitel if they would like 911 alerts enabled. 5 Mitel On-Site Solutions MiVoice Business MiVoice Business PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN. MiVoice Business PBXs licensed in the United States can be configured by the customer or partner to provide phone and console-based 911 alerts consisting of a visual display and a tone. The alert is capable of being sent to as many as 32 phones and consoles chosen by the customer. The alert, which contains the time and date of the call, the caller’s extension number as well as a configurable description of the caller, is initiated contemporaneously with a 911 call, and does not delay the call. Mitel recommends that 911 alerts be enabled in all MiVoice Business PBXs. Customers or partners currently using MiVoice Business PBX’s without 911 alerts are encouraged to enable alerts at this time. MiVoice Connect MiVoice Connect PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN. The MiVoice Connect PBX does not support notice to a central (or other location) when 911 is dialed. Mitel Revolution, which provides additional 911 alert functionality, can be purchased separately for use with MiVoice Connect. MiVoice Office 400 MiVoice Office 400 PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN. MiVoice Office 400 PBXs licensed in the United States can be configured by the customer or partner to provide phone and console-based 911 alerts consisting of a visual display and a tone. The alert is capable of being sent to as many as 32 Mitel SIP phones and consoles chosen by the customer. The alert, which contains caller name, the caller’s internal extension number, as well as a configurable description of the caller, is initiated contemporaneously with a 911 call, and does not delay the call. Additionally, a 911 notification email including caller name, extension number as well as a configurable description of the caller can be enabled. Emails are initiated contemporaneously with a 911 call, and do not delay the call. Mitel recommends that 911 alerts and emails be enabled in all MiVoice Office 400 PBXs. Customers or partners currently using MiVoice Office 400 PBX’s without 911 alerts and emails are encouraged to enable alerts and emails at this time. 6 Frequently Asked Questions • I don’t want notice of a 911 call to a central (or other location) enabled on my U.S. retail MiCloud Flex solution. As of Feb 16, 2020, notice of a 911 call to a central (or other location) will be enabled for all new retail customers in the United States. If you instruct Mitel to turn this feature off, Mitel will comply with your request, however any legal liability related to Kari’s Law will lie with your organization, not Mitel. Mitel recommends that you obtain independent legal advice prior to advising Mitel to turn off this feature. THIS DOCUMENT (AND ANY UPDATE(S) PROVIDED BY MITEL) MAY CHANGE FROM TIME TO TIME AND IS CURRENT ONLY AS OF THE DATE LAST UPDATED. PLEASE VISIT MITEL’S PARTNER PORTAL FOR THE MOST RECENT LATEST VERSION. THIS DOCUMENT IS INFORMATIONAL ONLY AND IS NOT LEGAL ADVICE. THE CONTENTS ARE “AS IS” AND WITHOUT WARRANTY. IN NO EVENT SHALL MITEL NETWORKS CORPORATION OR ANY OF ITS AFFILIATES HAVE ANY LIABILITY ARISING FROM OR RELATING TO THE INFORMATION CONTAINED HEREIN. MITEL RECOMMENDS THAT YOU OBTAIN YOUR OWN LEGAL ADVICE ON KARI’S LAW AND FCC 19-76. Last updated Feb 13, 2020. © Copyright 2020, Mitel Networks Corporation. All Rights Reserved. The Mitel word and logo are trademarks of Mitel Networks Corporation. Any reference to third party trademarks are for reference only and Mitel makes no representation of ownership of these marks. mitel.com