In a holiday surprise, the FCC’s Enforcement Bureau directed 2,411 companies to cure deficiencies in their Robocall Mitigation Database (RMD) certifications or explain why their certifications should not be removed. The deficiencies are due to lack of required information and robocall mitigation plans. Removal would require other providers to stop accepting calls from these companies.
The FCC established the RMD in 2020 and amended rules in 2023 to enhance information requirements and expand robocall mitigation plan obligations. As of February 26, 2024, providers must submit updated certifications with new required information and plans. Certifications must include details on robocall mitigation programs, STIR/SHAKEN implementation, company information, and commitments to respond to traceback requests within 24 hours.
The Wireline Competition Bureau identified providers that failed to update their RMD certifications by the February 26, 2024 deadline. These providers were notified on March 29, 2024 that they must submit updated certifications and plans by April 29, 2024. The 2,411 companies named in the Order still have not provided the required updates. The Order gives companies a final chance to update their certifications or explain why they should not be removed from the RMD. If removed, all voice service providers and intermediate providers would be prohibited from accepting calls from the named companies. The named companies have 14 days from the date of publication in the Federal Register to respond to the Order.
A copy of the Order may be found here: https://docs.fcc.gov/public/attachments/DA-24-1235A1.pdf. ECAC will continue to monitor the situation.
Mitchell Roth
mroth@rothjackson.com
