As automated “robocalls” continue to plague consumers, the Federal Communications Commission (“FCC”) is intensifying enforcement of robocall mitigation compliance.
On December 10, 2024, the FCC’s Enforcement Bureau (“Bureau”) released an order (“Order”) determining that nearly 2,500 providers across the calling chain, including voice service providers (“VSPs”), gateway providers, and non-gateway intermediate providers, had submitted deficient submissions to the Commission’s Robocall Mitigation Database (“RMD”).
As background, all voice providers must file certifications in the RMD to demonstrate their implementation of the FCC’s anti-robocall framework—referred to by the legislative name “STIR/SHAKEN”—on the IP portions of their network, describe their robocall mitigation plans, and provide other required information for ongoing compliance monitoring. Two immediate and severe consequences loom as a result of the Bureau’s Order:
- First, the providers identified in the Order must cure the identified deficiencies, or otherwise explain why they should not be removed from the RMD, and notify the Bureau within fourteen (14) calendar days of the date of the Order’s publication in the Federal Register.
- Second, all VSPs should closely review this Order; removal of a company’s certification from the RMD means that all intermediate providers and VSPs must cease accepting calls directly from that company.
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If you have any questions about robocalls, STIR/SHAKEN compliance, or the Order, please contact a member of Sheppard Mullin’s Telecommunications Team.