On January 25, 2024, the Wireline Competition Bureau released a Public Notice confirming the February 26, 2024 filing deadline for all providers (including all intermediate providers and providers that lack control over the network infrastructure necessary to implement STIR/SHAKEN) to submit new or updated information in the Robocall Mitigation Database (RMD), pursuant to the requirements adopted in the Sixth STIR/SHAKEN Report and Order (extending STIR/SHAKEN to intermediate providers) and Seventh STIR/SHAKEN Report and Order (which extended the gateway provider blocking and mitigation requirements to all carriers in the call path). Specifically, the Notice confirms and/or clarifies the following:
- By February 26, 2024, all providers are required to submit either new or updated Certifications and Robocall Mitigation Plans in the RMD, including the following information:
- Provider Information: The provider’s business name, address, and other identifying information
- Certification: The provider is required to file a certification stating:
- That all calls the provider originates on its network are subject to a robocall mitigation program,
- That any prior certification has not been removed by Commission action and the provider has not been prohibited from filing in the RMD, and
- Whether the provider has fully, partially, or not implemented STIR/SHAKEN on the IP portions of its network
- Additional Information on the Submission Form: the FCC has updated the RMD submission form to require new/additional information via checkboxes, dropdown menus, and text fields, including:
- The role(s) the provider is playing in the call chain (providers may indicate more than one provider-type, but note that the filing can only be associated with one FRN)
- Detailed information supporting any claimed STIR/SHAKEN implementation extension or exemption
- Information regarding the provider’s principals, affiliates, subsidiaries, and parent companies
- A statement whether they are subject to a Commission, law enforcement, or regulatory agency action or investigation due to suspected unlawful robocalling or spoofing and provide information concerning any such actions or investigations
- The filer’s Operating Company Number (OCN) if they have one.
- Robocall Mitigation Plan: The provider is required to include a robocall mitigation plan that describes the specific “reasonable steps” the provider has taken to avoid the origination, carrying, or processing of illegal robocall traffic as part of its robocall mitigation program, and includes other required contents, including:
- Voice service providers must describe how they are meeting their existing obligation to take affirmative, effective measures to prevent new and renewing customers from originating illegal calls
- Gateway providers, non-gateway intermediate providers and voice service providers must describe any “know-your-upstream provider” or “new and renewing customer” procedures in place designed to mitigate illegal robocalls, including any contractual provisions with end-users or upstream providers designed to mitigate illegal robocalls
- All providers must describe any call analytics systems they use to identify and block illegal traffic, including whether they use a third-party vendor or vendors and the name of the vendor(s)
- Beginning May 28, 2024, voice service providers and intermediate providers are required to refuse to carry traffic from any provider (including now, non-gateway intermediate providers) that is not listed in the RMD. [Note this date is later than initially reported]
The Notice also provides filing instructions.
Please see previous blog post FCC Announces Effective Date of Robocall Requirements.
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