May 6, 2021 Deadline to Have Robocall Mitigation Plan (RMP) and “Know Your Customer” Procedures Operational Fast Approaching; Deadline to Register and File RMP with FCC on the Horizon

Don’t become the FCC’s Poster Child for filing an inadequate, incomplete, non-substantive Robocall Mitigation Plan (RMP”) and avoid making the mistakes many Companies appear to be making with their RMP submissions; RMPs are NOT “Superficial” or “Certification” style documents; RMPs must contain “Substance” and “Details” regarding the specific steps your Company has taken to implement robocall mitigation measures, including Know Your Customer, data analytics, and other critical elements necessary to demonstrate the seriousness of your mitigation efforts. 

If your Company needs help, contact The CommLaw Group’s Robocall Mitigation Response Team now!

Voice Service Providers are On the Clock

June 30, 2021 is rapidly approaching. Virtually all voice service providers (“VSPs”) are required to make applicable STIR/SHAKEN filings with the Federal Communications Commission (“FCC”). Smaller SVPs (100,000 or less subscriber lines), while not required to make full STIR/SHAKEN filings, still must file robocall mitigation plans (“RMPs”) by that date. Moreover, SVPs must have their RMPs in place and operational by May 6, 2021.  The FCC has cast a wide net this time; even one-way SVPs and those who may have previously been exempt from certain regulatory requirements are required to file.  

The FCC’s RMP database is open, and SVPs are already beginning to file. It is extremely important that SVPs prepare and timely file complete and thorough RMPs; failure to do so will likely result in fines and other sanctions by the FCC, not to mention the fact that, because terminating carriers are required to check the RMP database, non-compliant SVPs risk having their calls blocked by the terminators.  

What RMPs Must Contain

The FCC requires that a VSP develop a RMP that:

  • details the reasonable steps taken to avoid originating illegal robocalls
  • demonstrates a commitment to respond to traceback requests to cooperate with investigations and stopping illegal robocalls
  • is filed in the RMP database.

While this may appear simple, the devil is in the details. The FCC is not shy about rejecting incomplete RMPs, which will effectively void them and subject the non-compliant SVP to the consequences listed above. Some of the RMPs that have been already filed appear incomplete and will likely be rejected by the FCC. 

A good RMP will contain detailed (but not necessarily lengthy) descriptions of an SVP’s:            

  • acceptable use policy
  • know your customer procedures (e. information that confirms the customer’s identity)
  • telephone number authorization
  • monitoring
  • investigation of suspicious activity and traceback
  • blocking
  • plan update information.
Ensure Compliance

In order to make sure that your company is compliant with the myriad of RMP requirements,  SVPs are well-advised to work with counsel who understands the nature of their businesses and can prepare RMPs tailored to their needs while meeting the FCC’s requirements.  The CommLaw Group is actively working with dozens of clients to develop their RMPs and other arrangements to ensure compliance. We have a template that we will send to any SVP which lays out the expectations and provides your company with the necessary regulatory guidance. We will also prepare and file your RMP.


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:
Ron Quirk – Tel: (703) 714-1305 / E-mail: 

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