State AGs encourage stronger robocall regulations

Forty-seven state attorneys general filed reply comments with the FCC to encourage them to strengthen robocall mitigation rules. In their letter, the AGs provide interesting information to explain why these rules would improve robocall mitigation. Let’s have a look.

The AGs explained that they have a strong interest in the Robocall Mitigation Database (RMD) filing rules because they use this information in their robocall investigations.

The following article lists several proposed rules that the AGs support, along with their reasons such rules are needed, which we found interesting.

Additional procedural measures

The AGs encouraged the Commission to provide better guidance to help filers certify more accurate information in their RMD filing.

For example, the AGs noted that several service providers with headquarters outside the U.S. and who can originate and terminate voice traffic outside of the U.S. do not check the box to indicate that they are foreign service providers. The AGs speculate that this is because the filer provided a business address in the U.S. Such inaccurate information hinders the traceback group’s efforts to investigate robocalls.

The AGs encouraged the Commission to require a filing fee. Such a fee would discourage bad actors from filing, as payment methods frequently provide a way to discover identifying information for filers who would otherwise remain anonymous. The AGs explain that the filing fee should be a modest amount levied annually.

Data validation

The AGs encouraged the Commission to adopt data validation tools for RMD certifications. For example, the process could validate the following:

• The business address given is valid in the U.S. Postal Service database.
• The business address given is not a residential or commercial mail-receiving agency.
• Corporate filers have an active corporate status in their state of incorporation.

Penalties and enforcement

The AGs encouraged the Commission to levy significant penalties on providers who file false or inaccurate information in the RMD.

The AGs support safe harbor for providers that block traffic directly from another provider flagged by the Commission for non-compliance with the RMD rules.

More information

• National Association of Attorneys General Reply Comments to FCC
• FCC Notice of Proposed Rulemaking

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