Robocall Mitigation Database filing statistics
We reviewed the progress of certification filings in the FCC Robocall Mitigation Database (RMD) and found some interesting statistics. Let’s take a look.
Filings by implementation type
The following chart and table show filings by implementation type as of June 9, 2021.
|Implementation||Count||% of All||% Without|
Intermediate providers comprise 44.7% of all filings. These filings were brought over by FCC staff from the Intermediate Provider Rural Call Completion database.
The remaining 505 filings, or 55.3% of all filings, were manually filed by other service providers. It’s a good start, but there are many more service providers that need to file by the June 30 deadline.
Of the manual filings, 38.6% are using some STIR/SHAKEN, either complete or partial. This is an interesting statistic. Many of these service providers probably could have claimed the small service provider extension. Instead, they implemented STIR/SHAKEN.
It seems the competitive advantage of offering SHAKEN call authentication to their customers outweighed any perceived advantage of delaying their SHAKEN implementation. Business customers want their outbound calls signed, and all subscribers would like to know that the caller ID for an incoming call was authenticated.
Looking at the providers that filed No SHAKEN, it seems likely that they rely on either TDM networks or interconnections.
Out-of-Band SHAKEN would enable these service providers to sign their outbound calls and verify SHAKEN signatures on inbound calls. We described the latest Out-of-Band SHAKEN specification in a recent press release and whitepaper.
Foreign service providers
Foreign providers that originate calls to the U.S. with U.S. NANP calling numbers must file a registration in the RMD, else their calls are to be blocked starting September 28, 2021.
So far, 23 foreign service providers have filed from 15 countries:
One might expect that these foreign service providers all filed as No SHAKEN. Fifteen did, but six filed Partial SHAKEN and two filed Complete SHAKEN. This is surprising. There are SHAKEN early adopters in countries that have not yet stood up a governance framework and do not yet require SHAKEN.
Robocall mitigation plans
Service providers that file either No SHAKEN or Partial SHAKEN also must upload a robocall mitigation plan. There have been 406 robocall mitigation plans filed.
The filing process allows a provider to request confidentiality for their robocall mitigation plan by filing a notice in the FCC ECFS regarding Docket 17-97. Thirty-seven providers filed for confidentiality and uploaded a redacted version of their plan. This represents 9.1% of the 406 robocall mitigation plans filed. Clearly, most filers are not concerned about the confidentiality of their plans.
We have looked at a sampling of reports. Most seem to be one page each. The longest we noticed was 16 pages, but it was fully redacted.
USTelecom has filed reply comments with the FCC to object to fully redacted robocall mitigation plans. In their comments, USTelecom states that heavily redacted filings undermine the transparency and accountability that public filings are intended to provide. It will be interesting to see how this plays out.
In addition, we help service providers with all aspects of STIR/SHAKEN deployment, including registering with the Policy Administrator and filing their Robocall Mitigation certification with the FCC.
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