FCC Releases NPRM on Updates to the Robocall Mitigation Database

On August 8, 2024, the Federal Communications Commission released a Notice of Proposed Rulemaking (“NPRM”) seeking comment on ways to improve the Robocall Mitigation Database (“RMD”).  The NPRM was adopted at the FCC’s August Open Meeting.

Specifically, the NPRM proposes and seeks comment on additional steps providers should be required to take in order to ensure the accuracy of the information submitted to the RMD. Specifically, the FCC:

1. Proposes to require that providers update information they have submitted to the Commission Registration System (“CORES”) within 10 business days of any changes (to ensure that the business name and address information automatically populated into Robocall Mitigation Database submissions from that system is current);
2. Proposes to require multi-factor authentication to access the RMD;
3. Seeks comment on requiring providers to obtain a Personal Identification Number (“PIN”) that must be provided before the RMD will accept a submission;
4. Seeks comment on requiring providers to pay a filing fee for RMD submissions;
5. Seeks comment on technical solutions that could scan RMD submissions, flag data discrepancies, and require providers to resolve such discrepancies before the filing is accepted by the system;
6. Proposes to establish a base forfeiture of $10,000, seeks comment on the maximum forfeiture amount for submission of false or inaccurate information to the RMD, and proposes to establish a $1,000 base forfeiture for failing to update information that has changed within 10 business days;
7. Proposes to authorize downstream providers to permissively block traffic by providers that have been given notice of facial deficiencies in the robocall mitigation plans and fail to correct those issues within 48 hours; and
8. Additional steps the FCC can take to encourage providers to submit accurate and complete information to the RMD and CORES and keep that information current.

Comments will be due 30 days after publication in the Federal Register, and reply comments will be due 60 days after publication in the Federal Register.

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