FCC Finally Releases Robocall Mitigation Plan Filing & Database Public Notice; Final Countdown to June 30, 2021 STIR/SHAKEN Compliance Deadline Starts… NOW!

On April 20, 2021, the FCC released its Public Notice that “announces the immediate opening of the Robocall Mitigation Database, provides detailed filing instructions, and establishes a June 30, 2021 deadline for voice service providers (“VSPs”) to submit required information in the Database.”  Beginning September 28, 2021, “intermediate providers and terminating voice service providers will be prohibited from accepting traffic from voice service providers not listed in the … Database.”

The TRACED Act requires all VSPs with an extension of the June 30, 2021 deadline to operate STIR/SHAKEN protocols in their networks to “implement an appropriate robocall mitigation program to prevent unlawful robocalls from originating on the network of the provider.”  The Commission extended the obligation to develop a robocall mitigation plan and file it with the FCC to all VSPs.  While the FCC did not prescribe the contents of a robocall mitigation plan, it did from time to time describe what factors should be addressed in a plan.  See M&D Client Alert on robocall mitigation plans. 

Specifically, the FCC required all VSPs to certify that:

  1. their traffic is either fully, partially, or not yet signed with STIR/SHAKEN;
  2. some or all of the calls they originate are subject to a robocall mitigation program to submit additional information with their certifications, including the type of extension or extensions received under section 64.6304 of the Commission’s rules;
  3. they have taken specific reasonable steps taken under a program to avoid originating illegal robocalls, and
  4. they made a commitment to respond to traceback requests and to cooperate with investigating and stopping illegal robocalls.

All required certifications must be signed by an officer in conformity with section 1.16 of the FCC’s rules.  As part of the certification, each VSP must provide:

  1. the business name(s) and primary address of the voice service provider;
  2. other business names in use by the voice service provider;
  3. all business names previously used by the voice service provider;
  4. whether the voice service provider is a foreign voice service provider; and
  5. the name, title, department, business address, telephone number, and email address of one person within the company responsible for addressing robocall mitigation-related issues.

The Public Notice provides details for filing instructions (https://fccprod.servicenowservices.com/rmd?id=rmd_welcome); Instructions for submitting a certification (https://www.fcc.gov/files/rmdinstructions); the location of the Database (https://fccprod.servicenowservices.com/rmd?id=rmd_listings) and instructions for requesting confidential treatment of submissions (https://www.fcc.gov/files/rmd-instructions).

Any updates or changes to VSP certifications, identification information, or contact information must be provided to the FCC within 10 business days of the change.  A list of VSPs that have submitted certifications, published as a .csv file, may be downloaded at any time at https://fccprod.servicenowservices.com/rmd?id=rmd_welcome.


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.   


Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com
Ron Quirk – Tel: (703) 714-1305 / E-mail: req@CommLawGroup.com 

ATTORNEY ADVERTISING DISCLAIMER: This information may be considered advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers