As discussed in a previous advisory, the Federal Communications Commission’s (FCC) Enforcement Bureau issued an Order on December 10 directing 2,411 providers to address deficiencies in their Robocall Mitigation Database (RMD or Database) certifications or risk removal from the Database. A summary of the Order was published in the Federal Register on December 17, 2024. The deadline to correct filings or explain why correction is unnecessary must be completed on or before December 31, 2024.
Companies on the list are advised to take action as soon as possible to ensure they do not experience any service disruptions.
Consequences of Non-Compliance
Under the FCC’s rules, the EB may remove deficient certifications from the RMD after providing sufficient notice and opportunity to cure. Under the Order, identified providers must cure their deficient RMD certification and notify the EB of compliance or explain why the Bureau should not remove the provider’s certification from the RMD within 14 calendar days of the publication of the Order’s summary in the Federal Register.
Failure to do so will result in the EB removing the provider’s certification from the RMD.
We previously communicated that if a provider is removed from the Robocall Mitigation Database, intermediate providers and other voice service providers are required to block its traffic, resulting in a significant loss of business for the removed provider. Reinstatement is possible but both costly and time-consuming, potentially taking up to a year, during which the provider would be unable to operate. The timeline may even be longer in the current situation, given the potential significant influx of reinstatement applications from providers that will be removed from the Database following this development.
Conclusion
Given the short response timeframe and potential significant business impacts of removal from the RMD, we recommend prompt attention to this matter. Our firm is available to assist with compliance reviews, certification updates, and FCC communications as needed.
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
Susan Duarte – Tel: 703-714-1318 / E-mail: sfd@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 James – Tel: 703 663-6757 / E-mail: daj@CommLawGroup.com
