FCC Establishes Dec. 31 as Deadline for Companies with Deficient Robocall Mitigation Database Certifications to Respond or Face Severe Consequences

FCC Establishes Dec. 31 as Deadline for Companies with Deficient Robocall Mitigation Database Certifications to Respond or Face Severe Consequences

In an Order released last week, the Enforcement Bureau (Bureau) of the Federal Communications Commission (FCC) notified 2,411 voice service providers that they have deficiencies in their Robocall Mitigation Database (RMD) certifications. A list of the companies is included as an attachment to the Order. Each company on the list must either notify the Bureau that the deficiencies have been cured or file a response explaining why the Bureau should not remove the company’s certification from the RMD. The deadline for filing a response is 14 days after publication of a summary of the Order in the Federal Register. Publication occurred today which established a December 31, 2024, deadline for companies to respond.

As explained in more detail in our September 10, 2024, e-Lert, effective February 26, 2024, carriers were required to update their RMD certifications to include the following information:

• Explicit details of any STIR/SHAKEN implementation extension rule applicable to your company and why it applies to your company
• Specific description of your company’s robocall mitigation techniques
• Whether or not call analytics are deployed in your network, if a vendor is used and the name of the vendor
• How your company knows its upstream providers
• How your company knows its new & renewing customers
• Commit to respond to traceback requests within twenty-four (24) hours
• Information regarding the filing entity’s principals, affiliates, subsidiaries, and parent companies, including information regarding any principal(s) that exercise management or control of the filing entity.

According to the Order, on March 29, 2024, the Wireline Competition Bureau (WCB) of the FCC notified each company whose certification was determined to be deficient that the certification must be updated to “cure” the deficiencies by April 29, 2024. Those companies who failed to cure these deficiencies by April 29, 2024, were referred to the Bureau.

In the Order, the Bureau provides companies whose names appear on the attached list one last opportunity to cure the deficiencies in their RMD certifications. The Bureau identifies two specific deficiencies that companies must address: (a) either no robocall mitigation plan was provided or the existing plan lacks the newly-required information, and (b) the certification itself lacks newly-required information. Companies must either cure both of these deficiencies and notify the Bureau that they have done so or explain why their certification should not be removed from the RMD. The Order warns, “Failure to comply with the Order will result in the removal of the company’s certification from the RMD, and all voice service providers and intermediate providers shall cease accepting calls from the company. “

Please contact Bridget Alexander White or call 301-459-7590 who can assist with helping your company cure your RMD certification deficiencies.

Numbering & Porting Essentials (NPE) Service

Clients interested in educating their staff on the multitude of numbering, porting, and Robocall Mitigation requirements all service providers must adhere to should consider subscribing to JSI’s Numbering & Porting Essentials service. The subscription includes breaking news alerts, and six web-based education sessions designed to keep companies informed about important numbering, porting and robocall mitigation decisions and requirements that will impact their internal operations and customers. The first session of 2025 will focus on the new Call Authentication and Robocall Mitigation rules. Click the button below or contact Bridget Alexander White for more details and to subscribe.

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