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New Deadline for Robocall Mitigation

The FCC has recently announced new compliance deadlines and requirements for Robocall Mitigation. All providers must file certifications and robocall mitigation plans to the Robocall Mitigation Database (RMD). The deadline is February 26, 2024. Additionally, the FCC has prohibited non-RMD traffic. What that means is that voice service providers must only accept calls from other voice service providers that have obtained RMD certifications.

In addition to the RMP and RMD certifications, voice service providers were required to implement the STIR/SHAKEN caller ID authentication framework by June 30, 2021. This framework helps to authenticate and verify caller ID information, making it more difficult for robocallers to spoof legitimate numbers. Carolina Digital Phone has been ahead of the pack and fully compliant for several years.

These new compliance deadlines and requirements are aimed at increasing the effectiveness of Robocall Mitigation efforts. In addition, they are designed to reduce the frequency of unwanted robocalls. Voice service providers are advised to ensure timely compliance with these requirements to avoid potential penalties and ensure the protection of their customers from robocall scams. If you are using a VoIP provider, are you sure they are compliant with the latest rules?

Who is Affected?

The FCC says all providers involved in the call chain must submit updated certifications and robocall mitigation plans to the Robocall Mitigation Database (RMD) by February 26, 2024. This applies to all providers, regardless of their STIR/SHAKEN status or whether they have the facilities to implement STIR/SHAKEN.

Do I need to take Action?

If the FCC informs any provider about any suspicious phone calls being made through their network, they must take action. The provider must immediately notify the Commission that they are not the provider originating or transmitting the calls. This applies to all providers – whether terminating or intermediate providers. They should also identify the upstream VSP that directly connects with the United States public switched telephone network and from where they received the call traffic. If possible, they should take legal steps to stop these calls. It is important to create a Robocall Mitigation Plan to combat unwanted calls.

A robust Robocall Mitigation Plan should incorporate various techniques and strategies. The plan must effectively address the issue of illegal robocalls and telemarketer scams. This plan should include the use of blocklists to block known scam numbers. Furthermore, it should include caller ID analysis to identify spoofed or suspicious numbers, caller ID lookup to verify caller information, call screening to filter out unwanted calls, and dynamic traffic analysis to detect patterns and anomalies in call data.

Combining these methods allows for a proactive approach to robocall mitigation. By using blocklists and caller ID analysis to automatically block and flag suspicious calls, organizations can reduce the number of illegal robocalls reaching their customers. Call screening and dynamic traffic analysis will further identify and filter out unwanted or potentially harmful calls.

It is crucial to emphasize the need for a long-term approach to robocall mitigation. Illegal robocallers are constantly adapting and evolving their tactics, so it’s vital to continuously update and improve a Robocall Mitigation Plan to stay ahead of these scams. By proactively integrating these techniques and strategies, organizations can effectively reduce the impact of robocalls and telemarketer scams on their customers.

New Requirements

The FCC also imposes specific additional requirements for the contents of RMPs filed in the database. First, voice service providers must describe how they are meeting their existing obligation to take affirmative, effective measures to prevent new and renewing customers from originating illegal calls. Second – non-gateway intermediate providers and voice service providers must, like gateway providers, describe any “know-your-upstream provider” procedures in place designed to mitigate illegal robocalls. Finally, all providers must describe any call analytics systems they use to identify and block illegal traffic, including whether they use a third-party vendor or vendors and the name of the vendor(s).

24-Hour Traceback Requirement

The Commission mandates that all VSPs, irrespective of their position in the call path, must promptly and comprehensively respond to traceback requests from the Commission, civil and criminal law enforcement, and the industry traceback group (“ITG”) within 24 hours of receiving such a request.

More Information

Effective Dates and Compliance Deadlines

Provisions related to Robocall Mitigation Database filing requirements and rules will be effective from February 26, 2024.

Compliance with 47 CFR § 64.6305(g)(4) is required no sooner than May 28, 2024.

Scope of Filing Requirements

All providers, regardless of STIR/SHAKEN implementation, must file certifications and robocall mitigation plans to the Robocall Mitigation Database.

Voice service providers, gateway providers, and certain non-gateway intermediate providers must implement STIR/SHAKEN.

Summary

The Federal Communications Commission (FCC) has recently released a Public Notice outlining the compliance deadlines related to their Sixth Caller ID Authentication Report and Order.

The Sixth Report and Order introduced extensive obligations regarding robocall regulations for all providers, regardless of their requirement to implement STIR/SHAKEN. These obligations include registering and certifying in the Robocall Mitigation Database (RMD), submitting Robocall Mitigation Plans (RMPs), and prohibiting the acceptance of traffic from providers not listed in the RMD. The new Public Notice sets deadlines for new compliance obligations.

If you have any questions about whether or not your voice provider is compliant with the latest FCC Robocall Mitigation deadline, now is the time to ask. If your current voice provider is unaware or nonchalant in addressing the latest requirements, you need to ask yourself if it’s time to find a new voice provider.

Carolina Digital Phone has been a leader in cloud-based Voice over Internet Protocol (VoIP) for over twenty years. Being experts in the field, you can trust that we are looking out for our customers. We would be happy to answer any questions you have about how we stay on top of rules and regulations, as well as the latest infrastructure and service innovations and enhancements. Call one of our specialists today at (336) 544-4000.