Today the Federal Communications Commission’s (“FCC”) Notice of Proposed Rulemaking, (“NPRM”) soliciting comments on proposed new stringent rules for Voice Service Providers (“VSPs”) regarding their filings in the Robocall Mitigation Database (“RMD”) was published in the Federal Register. Comments are due by October 15, 2024; and reply comments must be submitted on or before November 12, 2024.
As discussed in our August 9 Client Advisory, the proposed rules, if adopted, will burden VSPs with new costs and subject them to liabilities that could have severe negative impacts on their businesses. These proposals include:
- authorizing downstream providers to block traffic from VSPs that have been given notice of deficiencies in their robocall mitigation plans and failed to correct them within 48 hours;
- implementing technology that will scan RMD submissions, flag data discrepancies, and require providers to resolve such discrepancies before the submission is accepted by the filing system;
- imposing base ($3,000) and maximum ($10,000) forfeiture amounts for submitting inaccurate or false information to the RMD, or failing to update information that has changed within 10 business days (g., by cross-referencing information a VSP has listed in CORES);
- requiring multi-factor authentication each time a provider accesses the RMD;
- mandating that VSPs obtain a unique Personal Identification Number (“PIN”) that must be provided before the RMD will accept a submission; and
- requiring VSPs to remit a $100 filing fee for all submissions to the RMD.
The CommLaw Group Can Help!
The CommLaw Group’s wealth of specialized telecommunications law expertise, particularly our ability to see strategic implications of robocall rules and advocacy experience will enable our clients’ voices to be heard! Please let us know if you have any questions on this new development or would like assistance filing comments on the NPRM.
CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S ADVOCACY EFFORTS.
Jonathan Marashlian – Tel: 703-714-1313 / E-mail: jsm@CommLawGroup.com
Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com
Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com
Ronald E. Quirk – Tel: 703-714-1305 / E-mail: req@CommLawGroup.com
Diana James – Tel: 703-663-6757 / E-mail: daj@CommLawGroup.com