ARTICLE
17 December 2024

FCC Cracks Down: Are You Ready For The Robocall Mitigation Compliance Blitz?

SM
Sheppard Mullin Richter & Hampton

Contributor

Sheppard Mullin is a full service Global 100 firm with over 1,000 attorneys in 16 offices located in the United States, Europe and Asia. Since 1927, companies have turned to Sheppard Mullin to handle corporate and technology matters, high stakes litigation and complex financial transactions. In the US, the firm’s clients include more than half of the Fortune 100.
As automated "robocalls" continue to plague consumers, the Federal Communications Commission ("FCC") is intensifying enforcement of robocall mitigation compliance.
United States Media, Telecoms, IT, Entertainment

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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More