Telcos must refuse calls from unregistered providers

Starting September 28, 2021, FCC rules prohibit intermediate and terminating voice service providers from accepting calls with U.S. calling numbers directly from any voice service provider that does not appear in the Robocall Mitigation Database (RMD). Are you ready to implement this? Here’s how.

FCC rules

These rules appear in the Commission’s Second Report and Order on SHAKEN, Docket WC 17-97, paragraphs 86-94. The rules apply to the following calls:

• Have a U.S. NANP calling number
• Are received directly from an unregistered provider
• Includes calls received directly from foreign service providers, for example, international wholesale providers.

Here’s the exact rule from the Second Report and Order, paragraph 86:

We prohibit intermediate providers and terminating voice service providers from accepting voice traffic directly from any voice service provider that does not appear in the database, including a foreign voice service provider that uses NANP resources that pertain to the United States to send voice traffic to residential or business subscribers in the United States.

Notice that the registration requirement does not apply to the Originating Service Provider. It applies to the next upstream provider with whom the intermediate or terminating provider has a direct connection.

Compliance process

While we don’t provide either legal or regulatory compliance advice, we can describe the general shape of a process to comply with this rule:

1. Make a list of upstream service providers from whom you receive voice traffic directly, i.e., inbound trunks.
2. Look up these providers in the Robocall Mitigation Database.
   1. Click View Database.
   2. For each upstream provider, type the provider’s name in the Keyword Search box in the upper right of the browser window.
   3. Check that each upstream provider appears in the results. Note: you can click a provider row to see more information about their RMD filing. This will help you confirm that you’ve found the correct one.

Notice that this is an administrative process. You aren’t programming your network systems to check RMD status on calls as they enter your network. You’re just making sure that your inbound trunks represent registered providers.

We recommend that you start this review process sooner rather than later. This will help you identify any potential issues with upstream providers. You may wish to contact any unregistered upstream providers to understand what they’re doing about this.

This review does not end after September 28. You should perform this review periodically to make sure the providers from whom you receive calls are still in the RMD.

TransNexus solutions

We offer STIR/SHAKEN and robocall mitigation solutions in our ClearIP and NexOSS software platforms. We can make your STIR/SHAKEN deployment a smooth process.

In addition, we help service providers with all aspects of STIR/SHAKEN deployment, including registering with the Policy Administrator and filing their certification with the FCC.

We also offer robocall mitigation solutions for non-U.S. service providers. These solutions will enable you to have your calls accepted by U.S. service providers in compliance with FCC rules.

Contact us today to learn more.