JSI Reminds Clients of Robocall Mitigation Database Obligations

JSI Reminds Clients of Robocall Mitigation Database Obligations

The Federal Communications Commission (FCC) requires all voice service providers to mitigate originating robocall traffic and to document their mitigation efforts. The documented efforts are known as a Robocall Mitigation Program (RMP). The RMP, along with Robocall Mitigation certification, must be filed in the FCC’s Robocall Mitigation Database (RMD).

All RMPs on file must include the additional information the FCC required carriers to add by February 26, 2024. Carriers that did not update the RMP with the new required information by the February 26 deadline are now receiving FCC Notice of Failure to Comply with Robocall Mitigation Database Filing Requirements. The notice states the service provider must submit an updated certification and updated RMP in the Robocall Mitigation Database by the date listed in the non-compliance notice. If it does not do so, the provider will be referred to the FCC’s Enforcement Bureau for investigation.

If your company’s certification is not completed and/or the RMP does not include the following, your company’s RMD filing will be deemed deficient and in violation of the Commission’s rules.

• Explicit details of the STIR/SHAKEN implementation extension rule and why it applies to your company
• Specific description of your company’s robocall mitigation techniques
• Any call analytics deployed in your network, if a vendor is used, name of the vendor
• How your company knows its upstream providers
• How your company knows its new & renewing customers
• Commit to traceback response 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.

Failure to update the Robocall Mitigation Certification and Robocall Mitigation Plan in the Robocall Mitigation Database may result in removal of the provider’s existing, noncompliant certification and RMP from the Robocall Mitigation Database. If your company’s certification and RMP are removed from the RMD, voice service providers are prohibited from accepting traffic from your company.

Please contact Bridget Alexander White or call 301-459-7590 with any questions or to review your Robocall Mitigation Database filing.