Robocall Mitigation Database filing changes

June 14, 2023

Recent and proposed rule changes by the FCC will require voice service providers to update their certification filing and robocall mitigation plans in the Robocall Mitigation Database. This article provides a quick overview of the changes and timeline.

Robocall Mitigation Database overview

There are two types of information collected in the Robocall Mitigation Database (RMD): certification, and robocall mitigation plans.

Certification

RMD certification provides information submitted in a web form to identify the provider and claim a certification option, either Complete STIR/SHAKEN, Partial STIR/SHAKEN, or No STIR/SHAKEN.

There are separate certification options for voice service providers and gateway providers. This enables providers that perform roles to claim different STIR/SHAKEN implementations for each role where applicable.

Every telephone service provider in the U.S. is required to accept calls only from other providers that have a certification filed in the RMD. Therefore, all U.S. providers and foreign providers that send traffic to gateway providers in the U.S. must file a certification in the RMD.

Robocall mitigation plan

Currently, a robocall mitigation plan is required for any provider that claims either Partial STIR/SHAKEN or No STIR/SHAKEN.

If the filer is a voice service provider and must upload a plan, then the plan must include:

Explanation of the specific reasonable steps the voice service provider has taken to avoid originating illegal robocall traffic.
The type of extension(s) received under 47 CFR § 64.6304, if applicable.
A commitment to respond fully and in a timely manner to all traceback requests.

If the filer is a gateway provider, then the plan must include:

Explanation of the specific reasonable steps the gateway provider has taken to avoid originating illegal robocall traffic.
A commitment to respond fully within 24 hours to all traceback requests.

New requirements

In their March 2023 open meeting, the FCC adopted additional rules for robocall mitigation and STIR/SHAKEN.

The most notable rule change is that every provider in the U.S. will be required to perform robocall mitigation and file a robocall mitigation plan.

Furthermore, additional information will be required in robocall mitigation plans, including:

Additional info about the provider’s role(s) in the call chain,
More details to support claims that the provider does not have to implement STIR/SHAKEN,
Certification that the provider has not been prohibited from filing in the RMD,
A statement whether the provider is subject to an action or investigation by the FCC, law enforcement, or regulatory agency, and
The provider’s OCN.

The deadline for updated RMD filings will be 30 days after the publication in the Federal Register of the approval of these rules by the Office of Management and Budget. The OMB may have to do a review to comply with the Paperwork Reduction Act. As of the press date on this article, the rules have not yet been published in the Federal Register.

However, it would be smart to begin preparing your responses now.

Resources

TransNexus has developed a template for our customers to help them prepare their robocall mitigation plan. This template includes building blocks that respond to the information required in the new regulations for various provider roles.

TransNexus solutions

TransNexus is a leader in developing innovative software to manage and protect telecommunications networks. The company has over 20 years’ experience in providing telecom software solutions including toll fraud prevention, robocall mitigation and prevention, TDoS prevention, analytics, routing, billing support, STIR/SHAKEN and SHAKEN certificate services.

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