Groups Welcome Proposed Modifications to FCC Robocall Mitigation Database

There is a "proliferation of RMD entries that are flawed on their face," said USTelecom. Removing providers with "facially deficient filings" will "provide another strong tool for the industry to identify and stop bad actors," it said. USTelecom also backed deterring inaccurate filings. "Coupling removal with a strong penalty will discourage others from attempting to submit fraudulent filings to the database."

CTIA urged that the FCC "take steps to improve the accuracy and effectiveness of the RMD" by addressing the "threat posed by deficient filings." The group backed using the FCC's existing process to remove providers' RMD certifications if they fail to correct deficiencies in their filings. It also backed removing the certification of any provider that was the subject of an FCC order directing companies to stop accepting traffic from that provider.

Some proposals will be "unnecessarily burdensome," said Incompas and the Cloud Communications Alliance in joint comments. The FCC should let providers "cure deficiencies in the RMD without penalty," they argued. Incompas said its members' "primary concern" with the database is the "lack of clarity, best practices, and guidance" on registration requirements. Both groups sought "more specificity" about what must be included in a filing.

NCTA agreed. "Other than increasing the burden on providers and their individual officers in charge of the RMD submissions, these additional requirements will not increase the accuracy of RMD submissions," the group said. NCTA also raised concern about the FCC's proposal that would charge a fee for RMD filings, saying it "could discourage corrections to the RMD."

"Deficient entries within the RMD," said the Electronic Privacy Information Center, Public Knowledge and National Consumers League in joint comments, "just like deficient robocall mitigation itself, cannot be tolerated." The groups urged "swift enforcement" and backed the FCC using an expedited process to suspend deficient RMD entries. They also supported an RMD filing fee, encouraging "companies to get their filing right the first time."

NTCA asked the FCC to limit new RMD filing fees to voice service providers on an annual basis and amended filings submitted in response to an FCC inquiry regarding facially deficient robocall mitigation plans. "The RMD rules are in some cases confusing and vague," it said, and "corrections for ministerial errors highlighted by the commission upon review should not trigger an obligation to pay yet another filing fee."

ZipDX said RMD registrants should submit documentation that they filed a beneficial ownership information report with the Financial Crimes Enforcement Network. The company suggested a validation system that could be automated. ZipDX also agreed a filing fee is "appropriate" and "quite nominal for the (on-going) privilege of putting calls onto our public telephone network."

"Deploying validation tools that automatically check new RMD certifications in real-time," said iconectiv, will likely "save the industry significant time and resources." The company said that investing in data validation tools would improve compliance and "far outweigh the costs these voice service providers would incur in processing tracebacks if deficient robocall mitigation plans were not detected until an enforcement investigation."