Background
The Federal Communications Commission (FCC) has proposed improvements to its Robocall
Mitigation Database, which requires voice service providers to certify that they have
implemented caller ID authentication using STIR/SHAKEN standards and submit detailed plans
to mitigate illegal robocall traffic. Inclusion in the database is a prerequisite for operating as a
voice service provider in the United States.
Purpose
The proposed improvements aim to increase accountability and accuracy among filers, thereby
enhancing the database’s effectiveness as a tool in the fight against unwanted robocalls. The
FCC’s Robocall Response Team has removed providers from the database for failing to meet
their obligations, such as cooperating with robocall investigators and filing detailed mitigation
plans.
Proposed Measures
The Notice of Proposed Rulemaking seeks comment on several measures, including requiring
providers to update their Commission Registration System profile within 10 business days of any
changes, mandating multi-factor authentication and PIN numbers for database access, and
imposing filing fees for submissions. Additionally, it proposes technical solutions to validate data
and flag discrepancies, establishing separate penalties for submitting false or inaccurate
information, and authorizing downstream providers to block traffic from filers with facially
deficient robocall mitigation plans that fail to correct deficiencies within 48 hours.
Significance
The proposed improvements to the Robocall Mitigation Database aim to strengthen the FCC’s
ability to hold providers accountable for compliance with robocall mitigation rules, ultimately
protecting consumers from unwanted robocalls. The database plays a crucial role in facilitating
the implementation of STIR/SHAKEN and robocall mitigation rules, making it essential to
ensure its accuracy and effectiveness.
For companies that want to participate in the rulemaking, Comments are due October 15, 2024.
Reply Comments are due November 12, 2024.
Mitchell Roth
mroth@rothjackson.com
