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All existing Robocall Mitigation Database filers were required to submit updated certifications and robocall mitigation plans in the Robocall Mitigation Database by February 26, 2024.  These updates are necessary to comply with additional content requirements adopted by the Federal Communications Commission (“FCC”) in March 2023. 

We would like to inform our clients that the FCC is analyzing the robocall mitigation plans submitted to the Robocall Mitigation Database and privately informing the voice service providers whose filings are deficient that they must cure the deficiencies within a set deadline or be removed from the Robocall Mitigation Database.

Even if you have not been contacted by the FCC yet, failure to submit an updated robocall mitigation plan as soon as possible may result in the removal of the noncompliant certification and robocall mitigation plan from the Robocall Mitigation Database.  All intermediate providers and terminating voice service providers will be required to cease accepting traffic from any provider removed from the Robocall Mitigation Database. 

Moreover, beginning on May 28, 2024, voice providers and intermediate providers will be required to block all traffic from voice service providers who are not registered in the Robocall Mitigation Database. So, registration in the Robocall Mitigation Database is crucial for voice service providers to maintain their business.

It is crucial that your company has an updated and compliant certification and robocall mitigation plan in the Robocall Mitigation Database. Reinstatement in the Database may take anytime from 6 to 12 or more months, resulting in the loss of business for that time and legal costs.

NEED HELP WITH ROBOCALL MITIGATION, COMPLIANCE AND LITIGATION SUPPORT/DEFENSE AGAINST BUSINESS & LEGAL CHALLENGES?

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 and the private sector ecosystem), as well as the increased risk of business disputes, consumer protection enforcement by state attorneys general, and even civil litigation, 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.

CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S COMPLIANCE EFFORTS

Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com

Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com   

Ron Quirk – Tel: 703-714-1305 / E-mail: req@CommLawGroup.com

Diana Bikbaeva – Tel: 703 663-6757 / E-mail: dab@CommLawGroup.com

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