The Federal Communications Commission (FCC) required voice service providers (VSPs) to implement STIR/SHAKEN by June 30, 2021 on internet protocol (IP) portions of their network and file certifications on implementation status with the FCC via the Robocall Mitigation Database (RMD) by September 28, 2021 to avoid having their calls blocked.
Subsequently, the FCC exempted small VSPs from STIR/SHAKEN implementation until June 30, 2023 (but is formally considering shortening the exemption period). However, small VSPs must still file robocall mitigation plans (RMPs) in the RMD by September 28, 2021.
The FCC Wireline Competition Bureau issued carriers a reminder today to block calls from all carriers (including small VSPs) not listed in the RMD as of September 28, 2021 and provided an email subscription service to “ease compliance” with the call blocking obligation by providing a weekly update on RMD updates. The weekly update (sent Tuesdays at 11am for the preceding seven days) could result in calls blocked by carriers that choose not to manually review the RMD for updates. Any carrier submitting an RMP into the RMD as of today should work with counsel to ensure that terminating VSPs and intermediate providers are immediately notified to reduce or eliminate service disruptions and call blocking.
Our firm has contacted major terminating carriers to prospectively address dispute resolution issues for current and new clients that have filed RMPs in the RMD, but had calls erroneously blocked by those terminating carriers.
If you have not yet filed an RMP, the time is now! Contact the CommLaw Group now to assist with filing your RMP as soon as possible and taking proactive steps to ensure your traffic is not blocked and disruptions are minimized or eliminated.
NEED HELP WITH ROBOCALL MITIGATION AND COMPLIANCE?
|The CommLaw Group Can Help!|
Given the complexity and evolving nature of the FCC’s rules, regulations and industry policies & procedures around Robocall Mitigation and Compliance issues (e.g., Stir/Shaken, TRACED Act, FCC Rules & Regulations, US Telecom Industry group, ATIS, NECA, VoIP Numbering Waivers, Know Your Customer (effective May 6, 2021) and the private sector ecosystem), and anticipating the potential torrent of client questions and concerns, The CommLaw Group formed a “Robocall Mitigation Response Team” to help clients (old and new) tackle their unique responsibilities. The potential blocking of your company’s voice (and other) traffic due to non-compliance is very real, and very scary. Your company must be certain it achieves sufficient comfort knowing that it is doing everything it can, as efficiently and intelligently as it can, to achieve the level of compliance needed to avoid sleepless nights as the June 30, 2021 deadline approaches.
|CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S COMPLIANCE EFFORTS|